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AFFIDAVIT OF DANIEL P. SHEEHAN

these Defendants, some of whom have been
tagged by the press as "contrapreneurs/'
represent the very epitome of organized crime,
but on an international stage. They deal
wholesale in narcotic drugs, illegal weapons
and violence. Rather than take over local
businesses or undermine local government, they
seek to take over whole nations. They do not
hesitate to murder and destroy anyone or
anything that gets in their way. By any
dePmition, these Defendants, alleged merchants
of heroin and terrorism, are organized
criminals on a scale larger-than-life.'*

Filed on December 12, 1986
(Minor Revisions January 31, 1987)

Acknowledgement

If information contained in this Affidavit is reprinted,
rcbroadcast, or used in any way, we ask that you credit
the Christie Institute, an intcrfaith, public interest
law firm and public policy center.

The Christie Institute
1324 North Capitol Street, NW
Washington, DC 20002
(202) 797-8106

t
I

r I*

Table of Contents

Acknowledgement j

Introduction • ii

The Investigation Begins 4

"State Defense Forces'* and a "Guns for Contras" Scam
(8)

American Mercenaries and the Contras 9

A Honduran Meeting (9); An American Mercenary's Diary
(11); A White House Connection: North, Posey and Owen
(12)

Official, Covert U.S. Government Aid to Contras I3

Reagan Orders the CIA to Back the Contras (15); A
Congressional ban on "Direct or Indirect" Aid (16); The
"Privatization" of the Contra War (16)

The Hull Terror-Drug Operation: A Defector's Story j7

Cocaine and a Plan to Assassinate a U.S. Ambassador
(19); Contra Cocaine to the U.S. (22); The La Penca
Press Conference Bombing (23); Kidnappings, Death
Threats, and Murder (26)

The Secret Team 2S

The Wilson Connection in Iran (28); Supplying the

Contras (30)

The First "Contra War": Organized Crime and Right-wing

Terror-Politics j2

The Move to Southeast Asia: Political Assassination Financed

by Opium

The Birth of the Secret Team (36)

Post-Vietnam: Drugs, Arms Scams and Terror Continue 37

Early "Iran Arms Deal" Profit-Skimming (39)

The Contra Connection: The Secret Team Bargains with Somoza 40

The CIA Takes the Ball (41); North Turns to the Secret
Team When Congress Bans Aid (42)

White House Uses Secret Team Again for Iranian Arms Deal

Profits go to the Contra Operations 42

Conclusion

Photographs and Selected Index ! ! [ ! ] [ \ ] \ \ \ \ \ ] ; ; ; ; ; ~

Introduction

7^' document which you are about to read is derived from the most

comprehensive investigation, public or private, of the private
individuals involved in the Iranscam/Contragate affair. Months before
he Reagan Administration's admission that arms were sent to Iran a
lawsuit based on this investigation named the principal figures and
described their methods.

J^]! of years of investigative

work by the Christie Institute's professional private investigators; by
the plaintiffs. U.S. journalists Tony Avirgan and Martha Honey; and by
other investigative journalists. Its goal is to expose and bring to
justice the "Secret Team" of people which worked with the Reagan
Administration, through Lt. Col. Oliver North, to smuggle weapons to
Iran and to the Contras. This private operation has long been funded
by the sale of illegal narcotics in the United States.

The lawsuit is the only investigation outside of the federal
government empowered to use federal subpoena power to develop a legal
Vecord of truth" regarding this constitutional crisis. The legal team
IS already sharing information with the United Stated Congress
Investigative journalists now acknowledge that "this is bigger than
Watergate" and the Christie Institute is their primary private source
on the history and activities of the Secret Team.

The Christie Institute is a public interest, intcrfaith law and
public policy center. It has a reputation for through, professional
private investigations that result in significant legal victories It
IS best-known for launching and directing the successful Karen Silkwood
case. In 1985. the Institute won a civil judgement against the Ku Klux
Klan. the American Nazi Party, and the Greensboro Police Department
after state and federal prosecutions failed to obtain convictions for
the murder of peaceful anti-Ktan demonstrators.

The Affidavit

This affidavit is an unusual filing in a federal civil lawsuit
To advance to pre-trial investigation. Attorney Daniel Shcchan the
Plaintiffs- Chief Counsel and General Counsel of the Christie Institute
has submitted this sworn statement describing the results of three
years of private investigations. In it, he lays out a detailed
specific narrative of the defendants" criminal activities and' the
Christie Institute's investigation of them.

In the face of indifference and interference bv the Reagan Justice
Department. Christie Institute attorneys are acting as prosecutors
using the RICO (Racketeer Influence and Corrupt Organization Act)
Statute which was passed in 1970 to fight organized crime. Here RICO

is the cornerstone of an effort to prove the existence of the illegal,
private Contra support network involved in gunrunning, drug smuggling,
murder, political terrorism and other crimes and to bring its members
to justice. Leaders of this same network helped the Reagan
Administration secretly smuggle weapons to the government of Iran.

Created without use of federal subpoena power, the Affidavit
demonstrates the wealth of evidence available to those willing to look
for it. The sources have been kept, for the most part, anonymous.
Some seek immunity from criminal prosecution; others will testify only
if subpoenaed and forced to answer under oath; and many need to be
assured of their personal safety.

They include law enforcement officers, curren^ and former high
ranking officials of the Central Intelligence Agency and the Drug
Enforcement Agency, American mercenaries, individual contras, drug
smugglers and the pilots who have flown from the U.S. carrying guns and
returned with cocaine.

Because it summarizes an on-going investigation, minor revisions
have been made as new information becomes available. If information
contained in this Affidavit is reprinted, rebroadcast, or used in any
way, we ask that you credit the Christie Institute, an interfaith,
public interest law firm and public policy center.

Sheehan's investigation grew out of his work on the first
Sanctuary Movement defense case. In early 1984, he learned of Reagan
Administration contingency plans in the event of large scale U.S.
military action in Central America. The Federal Emergency Management
Agency (FEMA) had proposed imprisoning some 400,000 Central American
refugees already in the U.S. and the "deputizalion" and arming of
"State Defense Forces" civilians and military personnel intended for
domestic law enforcement.

According to sources within FEMA, a clandestine scheme to provide
weapons to the Contras had been proposed under the cover of a FEMA
training exercise. Weapons were to be dispersed to these local State
Defense Forces and then transferred to the Contras. Private networks
of American contra supporters were to handle the transfer of weapons.
Additional information on these private networks came to Shcchan
through a U.S. reporter with close contacts to American mercenaries.
With his help, Sheehan learned of the Reagan Administration's efforts,
directed by Lt. Col. Oliver North, to defy Congressional restrictions
and the eventual Congressional ban on aid to the contras by using
private war-makers.

Meanwhile, the plaintiffs, journalists Tony Avirgan and Martha
Honey, had been conducting their own investigation of the contras and
their U.S. supporters. Avirgan, while an ABC News cameraman, was
severely injured at the 1984 bombing of a press conference in La Pcnca,
Nicaragua. Supported by ihe Committee to Protect Journalists and the
Newspaper Guild, they discovered an "International Brigade" of

iii

gunrunners and terrorists fighting on behalf of the contras and based
in Costa Rica.

Avirgan and Honey identified this Brigade's main base to be
American John Hull's Costa Rican land holdings. Airstrips on Hull's
ranch helped transport both weapons and cocaine. The two reporters
discovered that this same group of men carried out the press conference
bombing and had planned to assassinate the U.S. Ambassador to Costa
Rica.

In 1985, Avirgan and Honey began sharing their information with
Sheehan. Sheehan's sources within the American intelligence community
soon led him to uncover, long before the public exposure of the Iran
Arms deal, a "secret team" of former high ranking Central Intelligence
Agency and U.S. military officials.

The Affidavit outlines this Secret Teams's history of political
assassination and arms trafficking funded by drug smuggling which begin
in the early 1960's. Sheehan's sources recount the team members' work
with anti-Castro Cuban terrorists and their leadership of
■unconventional warfare" programs in Southeast Asia. Sheehan's sources
told him of the development of a partnership there between opium
traffickers and the Secret Team, a continuing partnership which
provides the funding for independent, "black" operations after the
Vietnam War.

Later, while helping the Shah of Iran eliminate his opponents, the
Team made the connections which would be later used by the Reagan
Administration in the arms for hostages deal. When Nicaraguan Dictator
Anastasio Somoza was cut off from U.S. aid by the Carter
Administration, the Team stepped in with weapons and ammunition. They
were the Contras' primary early suppliers and later worked with the
Reagan Administration both before and after the Boland Amendment banned
any "direct or indirect" government aid to the contras.

AFFIDAVIT OF DANIEL P, SHEEHAN

Below, the Plaintiffs' attorney, Daniel P. Shcehan, sets forth for the
Court in the following Affidavit, the explanation of the evidence presently in
his possession which evidence does, in fact, rise to the level of "probable
cause" to believe that the Defendants named in this federal civil lawsuit are
guilty of the commission of the federal criminal violations set forth in the
Amended Complaint of October 4, 1986. The Plaintiffs move that this Affidavit
of Counsel be deemed a Supplemental Filing to their October 4, 1986, Amended
Complaint if the Court deems this to be legally required and that it be deemed
by the Court to set forth the evidentiary basis upon which a reasonable person
- drawing all logical inferences from the facts adduced in the direction of
the Plaintiffs - would conclude that it is more probable than not that each
of the Defendants named in this civil suit is guilty of violating the Federal
RICO Statute and that each is civilly liable to the Plaintiffs Tony Avirgan
and Martha Honey for having fortuitously contributed to the civil wrongs
committed against them as charged in this Amended Complaint as Supplemented
by the Affidavit of Counsel.

ATTORNEY DANIEL P. SHEEHAN

Now comes Attorney Daniel P. Shcehan, and having been duly sworn hereby
swears and affirms that the following facts are true:

1. I am a duly licensed attorney at law, admitted to practice before the
State and Federal Courts of the State of New York in both the Northern and
Southern Districts of New York.

2. I am duly licensed and have been admitted to practice before the Courts
of the District of Columbia, both local and Federal and I am in good standing
before both the Bar of New York and the Bar of the District of Columbia.

3. I have practiced law before the courts of New York and numerous other
states in our nation since 1970, having served as counsel in some 60 separate
pieces of litigation in the states of New York, Pennsylvania, North Carolina,
Virginia, the District of Columbia, Georgia, Florida, Oklahoma, Ohio,
Colorado, Idaho, Nebraska. South Dakota, Wyoming and Mississippi;

4* I graduated from Harvard College in 1967 as an Honors Graduate in
American Government, writing my Honors Thesis in the field of Constitutional
Law, and was the Harvard University nominee for the Rhodes Scholarship from
New York in 1967. I graduated from Harvard School of Law in 1970, having
served as an Editor of the Harvard Civil Rights-Civil Liberties Law Review and
as the Research Associate of Professor Jerome Cohen, the Chair of the
International Law Department of Harvard.

5. While at Harvard School of Law, I served as a summer associate at the
State Street law firm of Goodwin, Proctor and Hoar under the supervision of
Senior Partner, Donald J. Hurley, the President of the Boston Chamber of
Commerce and Massachusetts Senatorial Campaign Chairman for John F. Kennedy.

I
i

At this firm I participated in the case of BAIRD v EISENSTAT, under Roger
Slockcy, General Counsel for the Massachusetts Planned Parenthood League
(establishing the unconstitutionality of the Massachusetts anti-birth control
law) and in the Nevada case, under Charles Goodhue, III (establishing the
constitutional right to bail in criminal extradition cases, including capital
cases).

While at Harvard School of Law, I authored "The Pedestrian Sources of
Civil Liberties" in the Harvard Civil Rights-Civil Liberties Law Review and 1
served under Professor Milton Katz, the President of the International Law
Association, as the Chairman of the Nigerian Biafran Relief Commission
responsible for successfully negotiating the admission of mercy flights of
food into Biafra in 1968.

6. While serving as a Legal Associate at the Wall Street law firm of Cahill,
Gordon, Sonnett, Reindcl and Ohio under partner Floyd Abrams and in
association with Yale Law School Professor of Constitutional Law Alexander
Bickel, I participated in the litigation of such cases as the UNITED STATES v
THE NEW YORK TIMES (establishing the constitutional right of The New York
Times to publish the Pentagon Papers); UNITED STATES v BRANZBERG (litigating
the First Amendment right of professional journalists to protect the identity

of confidential news sources) and THE NEW YORK TIMES v THE JEWISH DEFENSE
LEAGUE (establishing the right of newspapers to refuse to publish proffered
paid political advertisements of their choosing).

While a Legal Associate of the Cahill, Gordon law firm, I was appointed
by New York City Mayor John Lindsey to be Legal Counsel to the Inmate
Association of the Manhattan House of Correction and was admitted to practice,
pro hoc vice before the United States District Court for the Western District
of New York with Professor Herman Schwartz in the case of IN RE ATTICA PRISON
INMATES V MANCUSO (which caused the reversal of the official New York State
Coroner's Autopsy falsely certifying that all 41 hostages held by the inmates
at Attica prison had been killed by having their throats cut by the inmates —
whereas, in fact, all 41 hostages had been killed by the gunfire from New York
State Police into Attica Prison's exercise yard from the parapets surrounding
the prison.) During this period, I also served as public interest counsel in
the case of CORTIGHT v. RESOR, (establishing the First Amendment Right to
Freedom of Expression of US Servicemen); in the case of IN RE LINDA JENESSE
(establishing the right of appearance on the ballots of New York of all
candidates who obtained the legally required numbers of signatures on their
petitions.) and in McGOVERN FOR PRESIDENT, INC. v MAYOR JOHN LINDSEY
(establishing the First Amendment right of candidates for public office to the
use of public park facilities).

7. In 1972, I served as the New York States Assistant Campaign Director in
Charge of Voter Registration for George McGovern for President and the New
York State Democratic Party; and as Special Counsel to the Scott Commission
associated with the Knapp Commission investigation of New York City police
corruption.

8. I then practiced as Litigation Associate to F. Lee Bailey in the Boston
Law firm of Bailey and Alch during the period when Gerald Alch was
representing James McCord, the electronic eavesdropping specialist in the
Watergate Burglary Case - the man who wrote the letter to Judge John Sirica

revealing the direct involvement of then President Richard M. Nixon and high-
ranking White House personnel in the unconstitutional Huston Plan and the
unlawful covcr-up activities in the Watergate Burglary Case.

9. 1 also served as Chief of Litigation for the national American Civil
Liberties Union office in the Rocky Mountain States where I served as Chief
Trial Counsel in some one dozen trials - including the First Amendment
criminal defense of the United Artist film "LAST TANGO IN PARIS"; the
successful Federal Civil Rights Act civil prosecution of the members of the
Idaho State Board of Education in LYMAN v SWARTLEY, et al. for the unlawful
termination of American Federation of Teachers union organizer Rufus Lyman

from the Idaho State University; UNITED STATES v STARR (dismissing Rap Brown
Act charges against students arrested in Nebraska for endeavouring to attend
funeral ceremonies in South Dakota for a member of the American Indian
Movement killed at Wounded Knee.) In this and many other cases, I served as
Co-counsel to the National Native American Rights Committee for the National
Office of the American Civil Liberties Union and as one of the Counsel in the
United States Supreme Court case of MANCARI v MORTON (establishing the
constitutionality of the preferential hiring of Native Americans by the
National Bureau of Indian Affairs).

10. After attending Harvard Divinity School, I served as General Counsel to
the United States Jesuit Headquarters* Office of Social Ministry in
Washington, D.C., in which capacity 1 served as National Chairman of the
Washington Inter-religious Staff Council's Task Force on Civil Rights and also
as the National Chairman of the Washington Inter-religious Staff Council's
Task Force on Criminal Justice, In this latter capacity, I served as the
primary Washington, D.C., lobbyist for the national religious community in
opposing the passage of Senate Bill One, the draconian Nixon-Mitchell Federal
Criminal Code.

In this capacity I also chaired the Civil Liberties and Religious
Community Briefing for United States Attorney General Griffin Bell in 1977.

11. Between 1976 and 1986, I served as Chief Counsel in the major
cnvironmenta; and civil rights case of KAREN G. SILKWOOD v THE KERR McGEE
NUCLEAR CORPORATION.

12. Since 1980, I have served as General Counsel and Chief of Litigation for
the Christie Institute, a 501 (c)(3) public interest law firm and intcrfaith
public policy center in Washington, D.C., serving as Chief Counsel in such

cases as THE PEOPLE OF THREE MILE ISLAND v THE GENERAL PUBLIC UTILITIE

CORPORATION, (successfully enjoining the General Public Utility Corporation

from venting radioactive materials from the damaged Three Mile Island nuclear

plant into the surrounding environment and compelling the corporation to

undertake court-approved clean-up methods); the successful first degree murder

defense of Mayor Eddie Carthan, the first elected black mayor in the

Mississippi Delta since the Civil War; and the winning of the dismissal of all

criminal charges against the staff of Catholic Bishop John Fitzpatrick of

Brownsville, Texas, who had engaged in aiding Salvadoran refugees in their

effort to obtain political asylum in the United Slates in the case of UNITED

STATES V STACEY MERKT.

The iDYestigation Begins

13. During the course of investigating the case of UNITED STATES v STACEY
MERKT, I was contacted, in March of 1984, in Brownsville, Texas, by a
Protestant minister. Source #1, and was informed by this Protestant minister,

that he had been contacted by an FBI field agent in the Brownsville area.
Source #2, and had been informed by this FBI agent that this agent had been
instructed by a superior in the United States Department of Justice, Source
#3, that undocumented Central American refugees being transported into the
United States by members of the Catholic Church participating in the Sanctuary
Movement included "known communist terrorists" who constituted "a potential
threat to the national security of the United States", in that such persons
were potential participants in "military cadres" to be launched against United
States military installations, domestic communications centers and domestic
water resource systems "in the event that President Reagan had to initiate
a direct military action by US forces into Central America, either into El
Salvador or into Nicaragua." This Protestant minister, who was reported to me
by the professional religious personnel of Catholic Bishop John Fitzpatrick to
be an honest and trustworthy source of information based upon their direct
experience with him, informed me that he had been warned by this FBI field
agent - whom the Protestant minister, in turn, knew to be an honest and
trustworthy source of information to avoid any contact with such
undocumented Central American refugees being aided by the Catholic Church
participants in the Sanctuary Movement, if the minister wanted to avoid being
caught up in trouble, in the event that President Reagan was forced to
undertake military action in Central America.

14. Being troubled by this report from an honest and trustworthy source,
after I completed the Preliminary Hearing for Stacey Mcrkt before the Federal
Magistrate in Brownsville, Texas, I returned to my office in Washington, D.C.,
and began a Preliminary Investigation to ascertain the source of this
unfounded accusation against my church and against the members of the
community of undocumented Central American aliens as I had come to know them.

15. In undertaking this Preliminary Investigation, I reached out to several
experienced and trustworthy professional investigators and professional
investigative journalists whom I was certain had trustworthy sources who could
locate the origin of this accusation. Among these investigators were:

SOURCE #4, a licensed, professional private investigator who is the
President of his State Association of Private Investigators, a member of
his Governor's Private Security Advisory Group in his state, a former
federal agent with a decade of experience working with members of the
military intelligence community, the FBI, the Central Intelligence
Agency, the US Customs Department, the DEA and various Slate Bureaus of
Criminal Investigation;

SOURCE #5, a professional research specialist for major national
television networks, newspapers, and law firms, and former Professional
Staff Member for a Committee of the United States House of
Representatives involved in investigations relating to Intelligence
Community and FBI abuses of citizens' rights;

SOURCE #6, a professional investigative journalist previously employed

as a staff investigator for syndicated columnist Jack Anderson, a staff
member of the Washington, D.C.-based investigative journalist
organization The Center For Investigative Journalism and a staff
investigative journalist for CBS Evening News; and

SOURCE #7, a former reporter with one of our nation's largest newspapers,
a reporter for a national wire service and a staff investigative reporter
for one of the national television networks.

16. At the end of March of 1984, I communicated to Sources #4. #5, #6, and #7
the information communicated to me earlier in March by Protestant Minister
Source #1 and I asked them to ascertain for me the source of this accusation

that the Catholic Church participants in the Sanctuary Movement were somehow
involved in smuggling into the United States "known communist terrorists" who
planned to form themselves, once inside the United States, into "military
cadres" to undertake the launching of military assaults against U.S. military
installations, domestic communication centers and domestic water resource
systems - in the event that President Reagan deemed it necessary to initiate
direct military action by U.S. forces in Central America, cither in El
Salvador or in Nicaragua.

17. During the second week of April of 1984, I was informed by Source #4 that
President Ronald Reagan had, on April 6, 1984, issued National Security
Decision Directive #52 authorizing then Federal Emergency Management Agency
Director Louis O. Giuffrida and his Deputy Frank Salcedo to undertake a

secret, nation-wide, "readiness exercise" code-named "REX 84". This exercise
was to test the "readiness" of the Federal Emergency Management Agency to
exercise civilian supervisory authority over defense department personnel, the
personnel of all 50 State National Guard units and numerous, state-based
"State Defense Force" units (which were to be established, at the behest of
FEMA, by state legislative enactments) - in the event that President Reagan
chose to declare a "State of Domestic National Emergency" concurrent with the
launching of a direct United States military operation into Central America.
This military operation was to be code-named "Operation Night-Train."

According to Source #4, the "mission" of the FEMA operation to be tested
pursuant to this REX 84 readiness exercise was two-fold. First, the Federal
Emergency Management Agency (after "deputizing" all DOD personnel and State
National Grand personnel - ostensibly so as to make such personnel
"civilians," and to, thereby, avoid violating the Congressionally enacted
Posse Comitatus Act^ would undertake to test its ability to seek out, and to
take into custody, some 400,000 undocumented Central American aliens
throughout the United States and, then, to intern said Central American aliens
m ten military detention centers, to be established during this REX 84

1 This Act of Congress forbids the use of any military
personnel, such as DOD or National Guard personnel for domestic
law enforcement purposes.

readiness exercise at ten U.S. military bases throughout the United States.^
These undocumented Central American aliens were to be held at these detention
centers during any real such Presidentially deemed State of Domestic National
Emergency, without the right of Habeas Corpus, until President Reagan declared
the State of National Emergency to be at an end.

The second "mission" of the FEMA operation to be tested pursuant to this
REX 84 readiness exercise was the distribution by FEMA, from U.S. military
bases under the supervision of the United Slates Department of Defense,
through the State National Guard Units, down into the hands of the civilian,
state-legislature-created State Defense Forces -- of hundreds of tons of small
arms and ammunition, ostensibly to be used by their civilian domestic law
enforcement "deputies" to enforce domestic laws, during the pending of the
Presidentially declared State of National Emergency.

18. The interest of the Christie Institute focused primarily on the first of
the two "missions" assigned to FEMA by this April 6, 1984 Presidential
National Security Decision Directive. This first mission was of direct
inimediate, interest to our law office in attempting to evaluate the "state of
mind" and attitude of the Justice Department personnel who were to be
"fielded" against us in the prosecution of the Sanctuary Movement personnel we
were retained by the Catholic Church to defend in Texas.

19. Upon learning of the existence of this REX 84 readiness exercise, I
reached out, through Sources #4, #5, #6, and #7 to find an "inside source" at
FEMA to either confirm or deny the intelligence information conveyed to me by
Source #4 regarding the planned readiness exercises named REX 84.

20. During the third week of April of 1984, Source #7 obtained for me an
introduction to Source #8 - a member of the Legal Division of the Federal
Emergency Management Agency, the office headed up by FEMA General Counsel
George Delt.

21. Source #8, who was known by Source #7 to be an honest and trustworthy
source of information based upon Source #7's direct experience with him, was
shocked that I had such accurate information concerning the content of
Presidential National Security Decision Directive #52, but he expressly
confirmed the accuracy of the intelligence report given to me by Source #4
concerning the two-fold mission of REX 84.

Source #8 expressed directly to me a high degree of fear and anxiety

2 These ten detention camps were to be located at:
(1) Fort Drum, New York; (2) Indiantown Gap Military Reservation,
Annvillc, Pennsylvania; (3) Fort A. P. Hill outside of the
District of Columbia in Virginia; (4) Fort Benning, Georgia; (5)
Eglin Air Force Base in Florida; (6) Camp Krome, Florida (this
base to serve as the jointly FEMA-INS Administration
Interrogation Center) (7) Ft. Chaffee, Arkansas; (8) Fort
Huachuca, Arizona - which was also to serve as the U.S. based
ground communication center for Operation Night-train; (9)
Vandenberg Air Force Base in California and one outside of
Oakdalc, California.

about the legality of what was being planned by FEMA General Counsel George
Jell, FEMA Director Louis O. Giuffrida and FEMA Deputy Director Frank Salccdo.
Source #8 reported to me that he had never before seen inside FEMA such an
intense level of security concerning any program. Source #8 reported to me
that FEMA General Counsel George Jett had ordered the installation of a
special metal security door into the hallway on the fifth floor of the FEMA
building in Washington, D.C. behind which door all of the planning for REX
84 was being conducted. Indeed, Source #8 reported to me that even long-
standing employees of the civil defense division of the Federal Executive
Department possessing the highest possible security clearances were not being
allowed through the newly-installed metal security door on the fifth floor of
the FEMA building to have access to the planning of REX 84. Source #8
reported that only FEMA Director Louis O. Giuffrida, his Deputy Director Frank
Salccdo, FEMA General Counsel George Jett - and a few other men whom Source
#8 noticed all wore a small red Christian cross, or crucifix pin, on the lapel
of their suits - were even allowed through the metal security doors on the
fifth floor of the FEMA building to have access to REX 84 information.

Through a Source #9, I was able to obtain a series of Federal documents
from inside FEMA which tend to confirm the above-reported description of the
FEMA activities reported to mc during April of 1984.

22. In early May of 1984, I was supplied by Source #4 with a number of
documents describing, in some detail, a project supervised by then Special
Assistant California State Attorney General Edwin Meese code-named "Project
Cable Splicer". This project, undertaken by Edwin Meese, under the direction
of then California Governor Ronald Reagan, took, then California Organized
Crime Training Institute Commandant, Louise O. Giuffrida from his post in San
Luis Obispo and made him the Commanding General of the California State
National Guard. At the California Organized Crime Training Institute,
Commandant Louis Giuffrida had been the Instructor in Civil Disorder Control.
As Commanding General of the California State National Guard, Louis Giuffrida
coordinated Project Cable Splicer for Special Assistant Attorney General Edwin
Meese and Governor Ronald Reagan.

Project Cable-Splicer was a special "war-games" readiness exercise
1 pursuant to which Governor Reagan, Special Assistant Attorney General Edwin

Meese and California State National Guard Commander Giuffrida could, together,
I establish an effective state of state-wide martial law "in the event that

I forces of radical black nationalism joined forces, inside the State of

California, with the anti-Vietnam forces to challenge the established
authority of the State." Project Cable Splicer was part of a larger program,
code-named "Project Garden Plot" — which was a nation-wide war-games scenario
prepared by then President Richard M. Nixon and his Attorney General John
' Mitchell designed to establish a nation-wide state of martial law if Richard

! Nixon's "political enemies" required him to declare a State of National

j Emergency.

"State Defense Forces" and a "Guns for Contras" Scam

23. In mid-May of 1984, I was informed by Source #10. who was a professional
journalist in New Orleans, Louisiana, that he had learned that the State
Legislatures of Louisiana, Alabama and Texas had sometime around April 1984 or
May 1984 each passed legislation establishing units known as '^State Defense
Forces". Source #10 informed me that he was extremely concerned about this
because the only people in Louisiana, Alabama or Texas who seemed to have
heard of the passage of these statutes and who were, therefore, signing up

to join these State Defense Forces were ultra right-wing para-military
"survivalist-types", or "soldiers-of-fortunc-types", who were being advised to
sign up for these State Defense Force units at weekend Survivalist Training
Centers or ultra-right "war-game** schools.

Source #10 informed me that this concern on his part had caused him to
undertake an investigation to ascertain what was going on regarding the State
Defense Force units in Alabama, Louisiana and Texas. Source #10 informed me
that he had discovered that a group of men in Texas who had all signed up for
the Texas units had been expelled by the Texas National Guard for being too
radically right wing. This investigation led him to a Louisiana State
National Guard Colonel, Source #11. Source #10 informed me that this
Louisiana State National Guard Colonel had informed Source #10 that the State
Defense Force unit in Louisiana was - in the near future - (this being in
May of 1984) going to be receiving a large quantity of small arms and
ammunition "in some kind of war game activity" supervised by the Federal
government - but that the State Defense Force in Louisiana "was only going to
have to give back half of the arms and ammunition received in the war-games.
The half which were left with them were going to be smuggled out of the
country to the Contras in Central America." This was to be achieved,
according to the Colonel, by re-valuing the weapons, while in the field, from
"manufacturer's" value to "replacement value", and then collecting the same
dollar value, as was originally distributed at the outset of the war-game.

Source #10 informed me that this Colonel had been proven, repeatedly, to
be a reliable source of accurate information, and that the arms and ammunition
which were to be left in the hands of the Louisiana State Defense Force Units
were to be secretly transported to a Louisiana warehouse owned or supervised
by a Louisiana state legislator (who had been active in obtaining the passage
of the State Defense Force statute). This legislator's name was "Woody"
Jenkins. The Colonel reported that from that point, the arms and ammunition
would be airlifted (mixed in with "humanitarian" aid for the Contras in
Central America) to Central America and given to the Contras -- "because the
liberals in Congress had cut off the Freedom Fighters when the CIA got caught
mining the harbors in Nicaragua".

24. My own investigations revealed the existence of one "Woody" Jenkins in
Louisiana, a man who was a Louisiana State Legislator of ultra right-wing
political persuasion, who was running an allegedly "humanitarian aid" airlift
to the Contras known as "Friends of the Americas."

25. I informed Sources #4, #5, #6, and #7 of the information communicated to
me by Source #10 and asked them to undertake inquiries to ascertain if any
similar activity was under way in either Texas or Alabama.

26. I was immediately informed by Source #7 that he w«s aware of a similar
type of operation functioning in the state of Alabama. Source #7 told me the
following information:

American Mercenaries and the Contras

26.1. That immediately prior to the Christmas holiday of 1983, Source #7
had been contacted by a fellow professional journalist. Source #12, who
had just returned home from a trip to Miami, Florida, where she had
learned of the location of a Contra military training camp in the
vicinity of Miami. She had learned that, in this camp, men were being
trained on United States soil to undertake direct military attacks upon

the citizenry and econonaic infrastructure of Nicaragua. Source #12
informed Source #7 of the location of this Contra training base near
Miami and suggested that Source #7 undertake a trip to this Miami area
Contra training camp to interview the men training persons there and the
men being trained.

26.2. Source #7 traveled to the location described to him by Source #12
in the vicinity of Miami, Florida over the Christmas holiday of 1983 and
found the Contra military training camp there, exactly as described to
him by Source #12.

26.3. Source #7, being fluent in both English and Spanish, interviewed
men doing the military training of Contras at this Miami vicinity base
and the men receiving the Contra training over the 1983 Christmas holiday
period.

A Honduran Meeting

26.4. During these interviews. Source #7 learned that there was a
contingent of former U.S. military personnel and active members of
various U.S. State National Guard units who were planning to organize an
unlawful, American-based, para-military organization to train, equip, and
finance - from U.S. soil - and actively to participate in military

field operations with the Contra forces in Central America against the
U.S.-recognized Government of Nicaragua. During these interviews, held
at the Miami area Contra military training base by Source #7 during the
1983 Christmas holidays, Source #7 learned that the U.S. citizens who
were organizing this unlawful American-based para-military organization
to be established to aid the Contras from U.S. soil, were planning to
hold a meeting at a particular hotel located in Tegucigalpa, Honduras in
January of 1984 to finalize specific plans for obtaining U.S. military
equipment for and providing other federally prohibited aid to the Contra
Forces.

26.5. Having failed to obtain permission from his United States based
newspaper to attend and to report on, this planned January 1984 meeting
of U.S. citizens at the Tegucigalpa hotel, Source #7 took a temporary
leave of absence from his newspaper and financed his own trip to

Tegucigalpa in January of 1984.

26.6. In January of 1984, Source #7 travelled to Tegucigalpa, Honduras,
and registered at the hotel described to him in interviews held at the
Miami Contra training base during the Christmas holidays of 1983. While
sitting in this hotel lobby, Source #7 observed numerous white adult male
U.S. citizens speaking English and dressed in various forms of camouflage
and war surplus U.S. military garb.

26.7. During his prolonged period of observation in this hotel lobby in
Tegucigalpa, Honduras, during January of 1984, Source #7 struck up a
conversation with a white adult male United States citizen who was a
participant in the para-military group meeting transpiring at the hotel.
Source #7 informed this person that Source #7 was an American writer
interested in understanding and publicly reporting on what was
transpiring at this Honduran hotel.

26.8. The white adult U.S. male with whom Source #7 had struck up this
relationship was Thomas Posey - the Defendant in the present Federal
civil lawsuit.

26.9. During these January, 1984 conversations at the Tegucigalpa Hotel
with Source #7, Defendant Thomas Posey described, in some detail, the
entirely illegal plan of action being developed by the U.S. participants

in the January 1984 meetings in Honduras. Defendant Posey described how
he and his associates were organizing an American-based group - which
was named the Civilian Military Assistance organization - the mission of
which was to recruit, train, finance, supply and to launch, from United
States soil, a foreign military expeditionary force, consisting of U.S.
citizens who were former members of the United States armed forces and
present members of various state National Guard units and anti-communist
Cubans, Nicaraguans and other Central Americans who wished to undertake
direct military action to overthrow the socialist government in
Nicaragua.

During these January, 1984 conversations with Source #7, Defendant
Posey expressed his opposition to the public policy and laws of the
United States Congress regarding Nicaragua, stating that Defendant Posey
and his Civilian Military Assistance organization were going to organize
and prosecute the war against the government of Nicaragua which the
United States Congress did not have the political conviction to allow the
official United States military to prosecute.

26.10. Between January of 1984 and mid-May of 1984, Defendant Posey had
several conversations with Source #7 during which conversations Defendant
Posey openly admitted his unlawful activities supplying military
equipment and explosives to Contra military and terrorist units in both
Honduras and Costa Rica -- with the express understanding and intention
that this military equipment would be used against the unarmed civilian
population inside Nicaragua to terrorize the people and to destabilize

the government of Nicaragua. Indeed Defendant Posey openly solicited
Source #7 to prepare and to publish, within the United States, reports of
Defendant Posey's convictions and activities so as to assist Defendant

Posey in his recruitment of U.S.- based contra supporters and in his
raising of money.

26.11. Source #7 personally attended Executive Committee sessions of the
leadership of the Civilian Military Assistance organization and
personally observed and heard planning sessions in which overtly criminal
operations were planned and agreed to by Defendant Posey, between January
and May of 1984. These activities Source #7 reported to me in May of
1984, requesting my analysis of the unlawful nature of the activities of
Defendant Posey and his associates in the Civilian Military Assistance
organization. I provided this legal analysis, pointing out that their
activities constituted a direct criminal violation of numerous federal
criminal statutes, including the Federal Neutrality Act, the Federal
Arms Export Control Act, various Federal Firearms and Explosives Statues
and other Federal and State laws.

An American Mercenary's Diary

27. Through Source #7, I was introduced to Source #13, a direct participant
in the high-level planning and execution of the criminal conspiracy of
Defendant Posey and his associates in the Civilian Military Assistance
organization.

28. Source #13, prior to the filing of the Civil Complaint in this case,
described for me, in detail, the Federal Criminal activities of Defendant
Thomas Posey regarding the obtaining of allegedly "surplus" U.S. military
equipment from the 20th Special Forces Unit of the United States Army in
Alabama and the obtaining of access to an allegedly "surplus" U.S. Armed
Forces airplane in New Jersey in which to transport this material from U.S.
territory, via Ilopango Air Base in El Salvador to Costa Rica, Honduras, and
Nicaragua. Source #13 described personally seeing crates of U.S. military
equipment (clearly marked as such) stacked in the private garage of Defendant
Thomas Posey awaiting transfer to the state of Florida, where the military
material was to be secretly flown to Ilopango Air Force Base for transhipment
to contra forces in Costa Rica and Nicaragua.

29. Indeed, Source #13 personally informed me of the existence of his hand-
written daily diary - into which he had made regular contemporaneous daily
entries from a period in 1983 all the way to 1986. He described certain
events memorialized in this diary - and 1 have personally reviewed a xerox
copy of this diary. Details taken from Source #13's statements to me and from
his diary arc set forth below in this Affidavit.

30. During my conversations with Source #13, he informed me that he was aware
of the identity of several men who had personally participated in the
transporting, loading, and flight of forbidden military equipment from the

State of Florida, to Ilopango Air Force Base in El Salvador, and from there,
onto the Costa Rican ranch of an American by the name of John Hull. This is
the same John Hull who is named as a Defendant in the present Federal Civil
lawsuit.

The men named by Source #13 are Source #14, one Jesus Garcia; Source #15,

one Steven Carr; Source #16, one Peter Glibbcry; Source #17, one Jose Cotinc;
Source #18, one Alan Saum; and Source #19, another individual with direct
personal knowledge of these illegal weapons and explosives transactions.

31. Either I, or one of my investigators or associates, have personally
interviewed each of Sources #13, #14, #15, #16, #17, #18. and #19 or they
have been directly interviewed by Source #20, Attorney John Mattes, the
Assistant Federal Public Defender in the United States District for Southern
Florida or his professional investigator. Source #21. The content of these
interviews have been communicated to me. These interviews set forth the
first direct, first-hand, knowledge of Sources #13, #14, #15, #16, #17, #18,

and #19 of the participation of Defendants Thomas Posey, John Hull and Bruce
Jones in the Federal Criminal Conspiracy to violate the Federal Neutrality Act
and the Federal Arms Export Control Act described in the Plaintiffs' Amended
Complaint. These facts, and the specific sources of the these facts will be
set forth below.

32. In June of 1984, I left Washington, D.C, to travel to the United States
District for Southern Texas, Brownsville Division, where I served as Chief
Trial Counsel in the case of United States v. Stacev Lvnn Merkt. et al.

A White House Connection: North, Posey and Owen

33. Upon returning to Washington, D.C, in late June of 1984, I was contacted
by Source #7 and was asked to meet with him. In this meeting. Source #7
informed me that, during the month of June of 1984, Source #7 had been
contacted by Defendant Thomas Posey, who had arrived in Washington, D.C
Source #7 stated that he had met with Thomas Posey, in Washington, D.C, in
June of 1984, and that Defendant Thomas Posey had physically introduced Source
#7 to one Robert Owen -- the same Robert Owen who is named as a Defendant in
the present Federal Civil Lawsuit.

I 34. Source #7 stated to me, in June of 1984, that Source #7 had met with

Defendant Robert Owen and Defendant Thomas Posey in a public park in
Washington. D.C, in June of 1984 and that Defendant Robert Owen, at that
time, stated to Source #7 that Robert Owen was a purely private citizen who
was acting solely in his purely private capacity to meet with the military and
political leadership of the Contras to communicate to them political advice as
well as to advise them in regard to what military equipment they might need to
carry out their military operation against the Nicaraguan Government. During
this June, 1984 public park meeting with Source #7, Defendant Robert Owen -Iso
stated that Defendant Owen was "taking orders" for weapons, military equipment
and explosives from the Contra military commanders in Central America and
seeing to it that their orders were filled and that the material was, in fact,
supplied to the Contras in Central America.

35. Then, during this same public park meeting with Source #7 in June of
1984, Defendant Robert Owen expressly stated to Source #7 that Defendant
Robert Owen was "the personal representative to the Contras of Marine Corps.
Lt. Colonel Oliver North, the Deputy Director of the United States National
Security Council for Political-Military Liaison" and that Defendant Owen was

acting privately to meet with the Contra Field Commanders as the "go-between"
for Lt. Colonel North - because Lt. Colonel North could not meet directly
with the Contra leaders, in light of the United States Congressional ban
against direct or indirect support being provided to the Contras by the
Executive Branch of the United State government.

At this meeting with Source #7 in June of 1984, Defendant Robert Owen
told Source #7 that Lt. Colonel North wanted Source #7 to travel to Costa Rica
and there to attend, and then to file a published report concerning, a secret
meeting which was to be held in Costa Rica among disparate Contra factional
leaders seeking to form a group to be called UNO the United Nicaraguan
Opposition. This was to be a coalition group of heretofore contesting Contra
military leaders whom Colonel North wanted to unify, in order to increase the
chances of the Administration to win Congressional approval to re-commence
diri^jct CIA funding and sponsorship of the anti-communist Contra forces.

36. Source #7 was surprised by the revelation made to him by Defendant Robert
Owen - so he sought me out immediately upon my return from Texas to discuss
the legal implications of what he had learned.

37. After my late June 1984 discussion with Source #7, I prepared a legal
opinion for Source #7. This legal opinion was provided to Source #7, a
professional journalist, with a view towards establishing a full scale
investigation to inquire into - and to expose -- what was going on out of the
White House office of Lt. Colonel Oliver North and in the states of Florida,
Alabama, and Texas among these private para-military organizations and Slate
National Guard forces.

38. During July of 1984, I traveled to the United States Middle District of
North Carolina to conduct the depositions of members of the Ku Klux Klan, the
American Nazi Party, the Federal Bureau of Alcohol, Tobacco and Firearms oC
the United States Department of the Treasury and the Greensboro City Police
Department who had participated in the planning and execution of the armed
assault upon the Workers Viewpoint Organization Anti-Klan March in which
marchers were murdered in 1979. I was,thcreforc, absent from Washington until
the end of 1984.

39. Indeed, throughout the first half of 1985, I was engaged full-time as
Chief Counsel in the prosecution of the federal civil case of Waller v.
Butkavitc h. et al. in North Carolina.

Orricial, Covert U.S. Government Aid to Contras

40. Upon my return to Washington, D.C, in the second half of 1985, I met
with my sources involved in the Posey-HuII investigation - and I was informed
that an American ABC television cameraman had been very seriously injured in a
May, 1984 terrorist bombing attack of the public press conference called by
former Sandinisia military commander Eden Pastora to denounce Adolfo Calero,
Calero*s FDN Contra organization, and the American Central Intelligence Agency
for trying to destroy Pastorals independent and nationalist Nicaraguan anti-
Sandinista force based in Costa Rica. I was informed by my sources that this
American ABC television cameraman had discovered that he had been injured in

1 t

an attack planned by Defendant John Hull and a Costa Rican-based anti-
Sandinista terrorist group supplied with C-4 explosives by Defendants Thomas
Posey» John Hull and Bruce Jones.

41. I expressed interest, on behalf of the Christie Institute, in hearing
from this ABC television cameraman named Tony Avirgan, and I was, soon
thereafter, contacted by Mr. Avirgan.

42. In my 1985 conversations with Tony Avirgan, with his fellow journalist
wife Martha Honey and with sources who were in direct contact with them
I learned the following facts - the particular sources for which will be
described later in this Affidavit.

42.1. That on July 17, 1979, Nicaraguan Dictator Anastasio Somoza
fled Nicaragua in the face of virtual universal condemnation of his
dictatorial and unjust regime, his unjust conduct having resulted, in
early 1979, in the total cut-off of all military assistance to his regime
by United States President Jimmy Carter under the dictates of the
Congressional Harkin Amendment (prohibiting any U.S. military aid to any
regime found to have systematically violated the human rights of its own
citizens).

42.2. Somehow, after the U.S. cut-off of military aid. Dictator
Somoza had found another source of U.S. military equipment which enabled
him to remain in office until July 17, 1979.

42.3. After his flight from Nicaragua, in July of 1979, former
Dictator Somoza set up several of his dreaded National Guard Generals in
Honduras, the neighboring country of Nicaragua, and proceeded to
supervise them in the mounting of a Xontra" military operation against
the 1979-officially-U.S.-recognized government of Nicaragua. No one
seemed to know from whence these "Contra" forces (as they came to be
called) were receiving their financing or their military supplies.

42.4. This "Contra" operation functioned under the direction of
former Dictator Somoza himself until he was assassinated in September of
1980 in Paraguay. The operation was, then, taken over and run by his
former generals from 1980 to 1981.

Still, no one knew who was funding or supplying this Contra force
with military equipment.

42.5. When Ronald Reagan took office as President of the United
States in January of 1981, a series of White House meetings took place -

attended by White House Chief of Staff Edwin Mecse; White House National
Security Advisor Richard Allen; United States CIA Director William Casey-
United States Vice President (and Chairman of the National Security
Council Task Force on Terrorism) George Bush and President Ronald
Reagan himself. In these meetings, it was discussed, and later agreed
that the United States CIA, under the direction of CIA Director Willikm
Casey, would "take over" the secret funding and military supply of the
Honduran-bascd, "Contra" forces.

Reagan Orders the CIA to Back the Contra*

42.6 ^° o*" '981. President Ronald Reagan signed a clas.ifirH

Nauonal Secur.ty Decision Directive expressly autho?izing'and dir c

? 5':"'"' !"'«"i8en« Agency Director William Casey to '

undertake the direct financing, training and military supply of the
Honduran-based Contra forces - but directing CIA Director Wil .am Casev
^oo^lv o7 '"dership that such CIA funding and '

L conl '0 Contras was to be conditioned upon

ni ,, mil. ary commanders organizing themselves into a coherent and
co-operat.ve un.fied coal.tion through which a centralized system of
Agency"* ^ ""'"^ ""^ conducted by the Central Intelligence

DirLnr WT^" ""'''^'^ Intelligence Agency

Casey assigned to CIA agent Vincent M Cannistraro tL

?i„tr/> A^""""^' ^'"^ '"PP'y °^ ^""'^^ ''"d -"fi'^^y equipment to the
Central American Contras. This operation began in June of 1981.

"^ LtK IT Jc" Proceeded, apace, throughout 1981 and into 1982

tTe States President Ronald Reagan repeatedly publicly denying

u.tl^Tf """^ ^'"^ °' involvement in supplying^

training or funding the so-called Contra forces in Central America

m,hii..« ^J'^u ''^"^ investigations and U.S. Congressional inquiries
publ cly exposed the fact that the White House was secretly funding and
supplying the Contras. President Reagan admitted the existence of "mTnor"
assistance to the Contras by the CIA - which assistance. President

fhe funntr/f' • '""'"'^ *° ''^'"^ Contra in "interdicting

the supply of weapons and military equipment flowing from the Sandinista
government of Nicaragua to the anti-government forces in El Salvado -

rili?" . . c U.S press and Congressional members pressed the Executive

?en^rT,;?,,n:,^rI^ ^"^8=^ gun shipments the

orelri 1 r.l^p '^S^"^. ."'"Sncd CIA agent David McMichaels to
M?MVK , Report establishing such traffic. When CIA agent David
McMichaels reported that there was no evidence to support the conclu k)n
that any such weapons trafficking existed from the Nicaragua n goveJnrnt
ScMfcSS"""""' ^' ^^'^ fired'agen?

ap,i„ vK^il^"* "^u"*"" '^'^ P"'"'<= position on the Contras

E HonlVr'- ' "''T'i ^'-^ being authorized by the

White House to support the Contras only to the degree necessary "to place

uo'tntf ' °" the government of Nicaragua 'to reform itsel ' to
BOvernmenX'^ 'u' P'"^^""**^ so<=i=ty. economy and form of

fhev lerthl f/vnTr Nicaragua by the Sandinistas when

tney led the revolution against Somoza."

tl^ u. ^ ^"'•c^' States Central Intelligence Agency was

c?vi?.a; hatbors''rf'L"''°"'- "^^'"^ P'="^ mice's ?n'the

Con r,^ I^I ? I '^^".='8"a - and for passing out "manuals" to the
Contras openly advocating the physical assassination of civilian

government authorities inside Nicaragua to bring about the overthrow of
that government. Both of these acts were violations of international
law. President Reagan, therefore, finally publicly acknowledged that it
was his objective to violently overthrow the officially-recognized
government of Nicaragua, "to prevent the establishment in Latin America
of a Soviet military base.**

A Congressional ban on '^Direct or Indirect" Aid

42.12. After a national and international uproar over the conduct of

the American CIA, Congress began to draft a piece of legislation to order
the cut-off of all military assistance - both direct and indirect -- by
the United Stales Executive Department to the Central American Contras.

The ''Privatization'' of the Contra War

42.13. Upon learning of this plan of Congress, White House Chief of
Staff Edwin Mcese. Vice President Bush, Central Intelligence Agency
Director William Casey, National Security Advisor Robert McFarlane and
NSC staff member Lt. Colonel Oliver North met and devised a method for
intentionally circumventing this Congressional ban.

42.14. In these meetings, this group decided to have Lt. Colonel
Oliver North establish contact with the secret group of private
individuals who had financed and supplied the military equipment to the
Contras prior to June of 1981 and to notify them that the White House
and the CIA would no longer be allowed to fund and supply the arms and
military equipment to the Contras after March of 1984.

In these meetings, this group also decided to have Lt. Colonel
Oliver North establish contact with Gray & Company (a Washington, D.C.-
based public relations and advertising organization) and to have Rob Owen
of that organization set up a private citizen-operated Contra support
group to publicly solicit funds and assistance for the Contras after the
up-coming prohibition of White House aid to the Contras. This operation
would give a feasible explanation for the source of the funding and
supply of the Contras so that Congress and the press would not
conclude that the CIA was still supplying the Contras.

This public organization was set up by Rob Owen by contacting
General John K. Singlaub - who, in turn, set up the United States
Council on World Freedom and began publicly raising funds for the
Contras.^

In fact. General Singlaub raised money inside the United
States which was directed, by him, to be deposited by
contributors in a Grand Cayman bank for use in the purchasing of
weapons and explosives for the Contras. Singlaub also travelled
to Central America with Robert K. Brown and personally
facilitated providing one John Henry "I.W." Harper to the
Contras, who trained Contras in the construction of C-4 anti-

The Hull Terror-Drug Operation: A Defector's Story

43. From my late 1985 conversations with Tony Avirgan, Martha Honey and their
sources, as well as from my direct personal conversations with one Carlos
Rojas Chinchilla, Source #25, I next learned the following facts^:

personnel bombs exactly like the one which was used to bomb the
La Penca press conference. In fact, Plaintiffs' Counsel has been
informed by Source #24 that Defendant Singlaub and Robert K.
Brown directly provided Harper to Defendant Amac Galil who helped
Defendant Galil construct the very C-4 bomb which Galil used to
blow up the May 1984 Eden Pastora press conference. Source #24
is a person with knowledge of the activities of Defendant
Singlaub, Robert K. Brown and John Harper with the Contras.

^ Prior to the La Penca bombing, Avirgan and Honey, in
their capacity as professional journalists, had developed well
placed sources within Eden Pastora's movement as well as Costa
Rican government officials who had provided them with detailed
information about the conflicts within ARDE and about CIA
maneuvers to force Pastora to join with the Honduran-based contra
movement, the Nicaraguan Democratic Alliance (FDN). They had
written articles for the New York Times and London Times and
worked on news reports for ABC television and radio detailing the
CIA pressures. They were aware beforehand that Pastora was
calling the La Penca press conference to denounce the CIA
maneuvers against him and to declare his refusal to join with the
FDN. Honey did not attend the La Penca press conference because
she was writing a story, which appeared on the front page of the
New York Times the day after the bombing, stating that the CIA
had given Pastora a 30 day ultimatum to join with the FDN and
that if he refused he would face unspecified consequences.

Immediately after the bombing, while Avirgan was still
recuperating. Honey was commissioned by the Committee to Protect
Journalists and the Newspaper Guild to undertake a through
investigation of who was responsible for the bombing. Avirgan
joined the investigation in August, as did several other
journalists based in Costa Rica. Over the next year, this team
carried out several hundred interviews and learned the following
information which was put into a report submitted to these two
committees.

Almost immediately they learned from ARDE officials and
contacts in Miami about a group of right-wing Cubans working with
the Costa Rican-based contras and involved in several attempts to
split contra commanders away from Eden Pastora. They were told
one of the group's leaders, Felipe Vidal, had discussed the need
to eliminate Pastora with a bomb and that Cubans in Miami had
discussed before La Penca eliminating Pastora and afterwards had
boasted to associates about carrying out the plot. Avirgan and

43.1. That in March of 1985, Carlos Rojas Chinchilla, a gainfully-
employed professional carpenter residing in the city of San Jose, Costn
Rica, was present at a public restaurant and bar named the Rendezvous Bar
located a few blocks from the United States Embassy in Costa Rica.

43.2. While present in this bar, after finishing work, Carlos Rojas
Chinchilla personally witnessed three men come into the Rendezvous Bar.
He saw them stop in the doorway for a short conversation and then Carlos
saw two of the men leave the bar. The third man was left standing in the
doorway. After a few moments of standing in the doorway, watching the
two other men depart down the street in the direction of the U.S.

Embassy, the man who had remained behind in the doorway of the bar turned
and began surveying the persons present in the bar.

43.3. This man's survey finally came to rest upon Carlos, and the man
briskly walked from his watch at the doorway and moved into the bar to
the table where Carlos sat.

43.4. The man told Carlos that his name was David, Source #26, and
that he had gotten himself involved in a situation from which he needed
someone's assistance to escape.

David explained to Carlos that David and his brother were
Nicaraguans who had joined the Contra forces in Costa Rica to fight
against the Sandinista government in Nicaragua. David explained that
David had, somehow, come to be part of a Special Unit of the Contra
forces in Costa Rica which made up a sort of "International Brigade**
physically based on the ranch of an American rancher by the name of John
Hull. David told Carlos that this American rancher was the supervisor of
this Special Unit or International Brigade and that the group operated
from John Hull's main ranch and other properties, some of which were
located on the northern-most boundary of Costa Rica abutting the river
which constitutes the southern border of Nicaragua.

Honey developed, over a number of months, a close relationship

with Felipe Vidal and from him and several of his associates,

learned that these Cuban were involved in forming an

"International Brigade" to provide military trainers and military

supplies to the contras, that a numbers of the leaders were tied

to the CIA, and that a number of the members had been involved in

terrorist and drug trafficking activities. They also learned

that John Hull, Bruce Jones and Rene Corbo were leaders of the

Brigade and there were strong indications that Vidal, Hull, Jones

and Corbo had been involved in La Penca.

Avirgan and Honey and their colleagues also gathered
information indicating that members of the FDN and ARDE as well
as some Costa Rican governments officials had been involved in
the planning, carrying out and covering up of the bombing.

Avirgan and Honey also were told by security officials in
several countries, contras, and people in Miami that the FDN was
behind and had authorized and financed the bombing

Cocaine and a Plan to Assassinate a U.S. Ambassador

43.5. David told Carlos, in this early 1985 meeting, that this
International Brigade supervised by John Hull had been directly
responsible for the May 30, 1984 bombing of the Eden Pastora press
conference - and that the same group was, at that very moment, actively
engaged in going forward with a plan to carry out a terrorist bombing of
the United States Embassy in San Jose, Costa Rica and a plan to
assassinate the new United States Ambassador to Costa Rica, Lewis Tambs.
David stated to Carlos that the two men with whom David had arrived at
the bar were, at that moment, "casing** the U.S. Embassy down the street

in preparation for the future bombing of the installation.

David explained to Carlos that the International Brigade supervised
by John Hull and housed on his ranch to the north of San Jose was
directly involved in the trans-shipment of large quantities of Colombian
cocaine from the airstrips on John Hull's farm (airstrips which had
recently been lengthened and improved to accommodate aircraft arriving at
John Hull's ranches with loads of military equipment, weapons, ammunition
and explosives). Other sources informed the Plaintiffs that this cocaine
came from one Jorge Ochoa and one Pablo Escobar, the two largest cocaine
producers and exporters in Colombia - and that the cocaine was being
moved from John HulTs ranch into the United States where it was sold, a
portion of the profits going to John Hull and his International Brigade
to help finance the guns, ammunition and explosives being used in their
military effort against the government of Nicaragua.

David told Carlos that in addition to bombing the Embassy, the
International Brigade intended to kill a U.S. diplomat who he later
identified as Ambassador Lewis Tambs. David told Carlos that the bombing
and the assassination of Tambs would be made to look like the work of the
Sandinista government of Nicaragua in an effort to instigate direct
military action by the United States against Nicaragua.

Other sources later told the Plaintiffs that the International
Brigade was also aware that Pablo Escobar had put a $1,000,000 dollar
"bounty" on the head of Ambassador Lewis Tambs. Escobar was reportedly
infuriated at the efforts made by Tambs, when Tambs was U.S. Ambassador
to Colombia, to obtain an extradition treaty between Colombia and the
U.S. which would allow the extradition of Escobar and other cocaine
traffickers to the U.S. for prosecution for drug smuggling. The
International Brigade hoped to additionally collect the $1 million bounty
to aid them in their purchase of military equipment for use in their
military effort against Nicaragua.

43.6. David told Carlos in this conversation that David did not want
to participate in this International Brigade any longer — that he did

not support the activities of the group directed against the U.S. Embassy
and Ambassador Tambs and he did not support the activity of the group
involved in drug smuggling to finance their operations.

But David told Carlos that David needed help in escaping from the
group that everyone in the group was watched by everyone else, as a
precaution against dissention and revelation of their activities. David
needed an "outside" person, someone who could help David and his brother

(who was fighting elsewhere with the Contras), escape without observation
by members of the International Brigade. David asked for Carlos' help.

43.7. Carlos refused, pointing out to David that Carlos was a
married man, with a wife and three children - and that Carlos lived in
a small row house with his wife*s beauty shop on the ground floor, a
place where any stranger, such as David or his brother would surely be
noticed if they tried to hide there.

43.8. David pleaded for Carlos to help and told Carlos to look for
him around the Embassy or at a town in northern Costa Rica, if Carlos
decided to help him.

Then David was gone, as the two men with whom he had arrived
returned.

43.9. Carlos went out of the bar after the men left and saw them
enter a large, gray car, without any license plates, and depart.

Carlos went to the home of his mother and informed her as to what
had occurred and sought her advice. She directed him to stay out of it
and to do nothing.

In a move to enforce Costa Rica's official policy of neutrality
towards Nicaragua, Costa Rican Rural National Guardsmen raided, in late
April 1985, a contra camp located on property near the Nicaragua border
managed by John Hull. They arrested nine Nicaraguan contras, five
foreign mercenaries including two Americans, and seized significant
amounts of guns, cannons, ammunition and explosives. This equipment
included guns and military equipment smuggled from Florida's Ft.
Lauderdale Hollywood Airport on March 6, 1985, by Sources #14. #15. #16
and #17. and Defendants John Hull, Bruce Jones and Thomas Posey.
Indeed, specific weapons expressly purchased and registered in the
United States by Defendant Thomas Posey were seized by the Costa Rican
Rural Guard on John Hull's ranch in early 1985, and are presently
available as evidence.

When Carlos Rojas Chinchilla learned of this Rural Guard action,
he realized that the description of the ranch, the name of the owner of
the ranch and the description of the man arrested and the equipment
seized all matched, exactly, the description of the International
Brigade described by David to Carlos in their early 1985 meeting at the
Rendezvous Bar.

This caused Carlos grave concern, since this ability of David to
describe so exactly the characteristics, equipment and locale of the
International Brigade arrested by the Costa Rican Rural Guard convinced
him that David had communicated to him equally accurate information
about the plans of the group to bomb the U.S. Embassy and to
assassinate U.S. Ambassador Lewis Tambs.

44, Following the arrest of the mercenaries on Hull's property, Carlos
Rojas Chinchilla realized that David's story had some basis in fact. He
sought the counsel of the only North American he knew, a woman neighbor
married into a Costa Rican family friendly with his family. Carlos
communicated the information to the members of this North American family,

Sources #29, #30, and #31, which had been told to him by David.

45. As it turned out, the daughter of this North American family. Source
#31, knew the Plaintiffs Tony Avirgan and Martha Honey and, following her
receipt of this information from Carlos, Source #31 contacted Tony Avirgan
and Martha Honey and informed them of the content of the meeting between
Carlos and David.

46. Tony Avirgan and Martha Honey, through Source #31, contacted Carlos
Rojas Chinchilla in 1985 and persuaded Carlos to attempt to reestablish
contact with David.

47. In 1985, Carlos did reestablish contact with David - and, at the
request of Tony Avirgan and Martha Honey, Carlos met with David and asked
David to explain, in detail, the information David possessed about the La
Penca bombing, about the activities of the so-called "International Brigade"

of Contra supporters operating from John Hull's Costa Rican ranch - and
about what David knew about the future plans of this Brigade.

48. In a series of meetings between David and Carlos held over the ensuing
weeks, David shared with Carlos the information which follows - some of
which was tape recorded by Carlos and some of which Carlos orally repeated
to Tony Avirgan, Martha Honey and Source #31 immediately after his
interviews with David.^

49. Both Tony Avirgan and Martha Honey spoke, by telephone, with David,
confirming his existence, his name and his possession of the general
information set forth below. But David would not meet directly with the
journalists. However, Plaintiff Avirgan did physically see David at a
distance, meeting with Carlos, on one occasion from which meeting Carlos
returned and shared more information with the Plaintiffs which came from
David.

50. In his direct interviews with David, Carlos was given the following
information - which fact Plaintiffs' Counsel has personally confirmed from
direct interviews with Carlos.

50.1. David told Carlos that David and his brother, who were
Nicaraguan citizens, had grown disillusioned with the Sandinistas
government in Nicaragua, and left Nicaragua and had joined the Contra
forces based inside Costa Rica.

50.2. David's brother was no longer with David, but was, rather, off
fighting somewhere else with the Contras against the Nicaraguan
government.

50.3. David had somehow come to be assigned to a group of men made up

Plaintiffs' Counsel is in possession of said tape recording and notes
from these interviews with David.

of Nicaraguan Contras» cx-patriot Cubans from Miami, foreign
mercenaries, and soldier of fortune types who were based upon the
cattle ranch and citrus farms owned or managed, directly on the Costa
Rican side of the Costa Rican-Nicaraguan border, by a millionaire
American rancher by the name of John Hull, the same John Hull named as
a Defendant in this suit.

50.4. Working with John Hull was another American rancher who owned a
ranch near that of John Hull. This man*s name was Bruce Jones, and is
the same Bruce Jones named by Plaintiffs as a Defendant in this suit.

50.5. Both Hull and Jones had earlier been directly associated with
agents of the American Central Intelligence Agency and had given over
their ranches as ''staging areas" for the landing and off-loading of
American CIA-supplied weapons and ammunition which were being supplied >
by John Hull to the Contra forces based in Costa Rica and just across

the border inside Nicaragua. This information came from sources other
than David, prior to contact with David.

50.6. David was a part of this "International Brigade" of Contras and
mercenary Contra-supporters and shared the Contra desire to overthrow
the Nicaraguan Sandinista government by military force.

50.7. However, in 1983, one of the Costa Rican-based military
commanders of the Contras, who was being supplied with military
equipment by the American CIA through John Hull, one Eden Pastora,
began to have difficulty with Hull and the CIA's man who was repeatedly
on John Hull's ranch. This CIA man was one Duane "Dewey" Claridge. As
a result, the CIA kept starting, and then stopping, the supply of arms

to Eden Pastora. Hull and Dewey Claridge were angry with renegade
Contra commander Pastora, because Pastora would neither accept
supervision from American CIA personnel sent in to Costa Rica to
provide "advice" to Pastora, nor would Pastora agree to integrate his
Costa Rican-based Contra forces into a unified Contra command under the
leadership of the Honduran-based FDN led by one Adolfo Calero and
former Nicaragua dictator Anastasio Somoza's former National Guard
generals. (This information came from sources other than David -
prior to David's contact with Carlos as did the information in 50.8
to 50.10 below.)

50.8. In mid-1983, a number of Cuban-Americans from Miami arrived at
John Hull's ranch and asked John Hull to arrange a meeting between
these Cuban-Americans and representatives of Contra commander Eden
Pastora with a view toward Pastora's agreeing to allow these Cuban-
Americans to bring down to Costa Rica a number of their Miami-based
Cuban-American associates to fight against the Sandinistas as part of
Eden Pastora's ARDE forces.

Contra Cocaine to the U.S.

50.9. When this request of the Cuban-Americans was rejected by Pastora

in May or June of 1983, two of these Cuban-Americans, one Felipe Vidal
and one Rene Corbo began setting up a cocaine trans-shipment operation
on John Hull's ranch.

50.10. Felipe Vidal and Rene Corbo coordinated the landing of small
planeloads of cocaine flying onto John Hull's ranch --and onto the
numerous other ranches "managed" by John Hull which were adjacent to
Hull's ranch along the Costa Rican border with Nicaragua. The cocaine
on these planes came from one Jorge Ochoa and one Pablo Escobar - the
two biggest cocaine producers and traffickers in Colombia. On John
Hull's ranches, this Ochoa-Escobar cocaine was off-loaded and then
trans-shipped up into the United States* going to Miami, New Orleans,
and Memphis.

50.11. David told Carlos that David was totally opposed to this
cocaine smuggling. But he said that a portion of the income earned by
John Hull, Felipe Vidal, Rene Corbo and their fellow Contra-supporters
by their participation in this drug smuggling network was being used to
help finance the purchase of military equipment, ammunition and
explosives needed by the Contras to wage their private war against the
Sandinista government.

50.12. This drug smuggling dimension of the John Hull-International
Brigade caused David to seriously consider fleeing from the operation.
But he did not.

The La Penca Press Conference Bombing

50.12.1. Carlos asked David to explain the role which members of
this International Brigade of Contras had played in the
May 30, 1984 terrorist bombing attack on the Eden
Pastora press conference at La Penca, Nicaragua.

50.12.2. David went into great detail explaining this role
informing Carlos that David had been personally informed
of his information by Alvaro Cruz and Frederico Saenz,

the two men on John Hull's ranch under whose direct
supervision David operated in his activities as part of
the Contra International Brigade.

50.12.3. Cruz and Saenz had informed David that the prePminary
decision to assassinate Eden Pastora had been made by
John Hull, Felipe Vidal, Rene Corbo and Adolfo Calero in
a series of meetings in or around January of 1984 —
when it became clear to these men that Pastora was
neither going to allow non-indigenous Nicaraguans, such
as the Cuban-Americans, to participate in his Costa
Rican-based ARDE military effort against the Nicaraguan
government nor was Pastora going to allow his Costa
Rican-based ARDE forces to be melded into a unified
Contra command under the leadership of Adolfo Calero's

Honduran-bascd FDN Contra force.

50.12.4. David reported that this January, 1984 preliminary
decision to kill Pastora had been made in meetings held
on John HulTs ranch among Hull, Vidal and Corbo and,
later, between these men and Adolfo Calero in Honduras.

50.12.5. Other sources reported that this preliminary decision

was finalized in a meeting in Miami, Florida in February i
of 1984, between Vidal and Corbo and their "sponsor" !
Francisco "Paco" Chanes. ]

50.12.6. It was Cruz and Saenz who informed David of the 1984
decision to conduct the bombing of Pastora. Other
sources set forth below hav^e verified specific steps in
this chain of events. They arc as follows:

50.12.7. In February of 1984, Felipe Vidal and Rene Corbo flew
from San Jose, Costa Rica to Miami, Florida - where
they met personally with Francisco "Paco" Chanes.
Chanes was the de facto owner of two Miami-based seafood
import companies. These were Ocean Hunter, Inc. and Mr.
Shrimp. These two private companies were, in fact, the
vehicles through which Francisco "Paco" Chanes smuggled
into the United States up to one full ton of Colombian
cocaine eiich week from Jorge Ochoa and Pablo Escobar,
via John Hull's Costa Rican ranch. "Paco" Chanes was
also an ardent financial supporter of the ultra right-
wing, Miami-based, Cuban anti-communist organization
"Brigade 2506," Silent partners in Chanes' two "seafood
import" companies were Frank Castro and Rolando Martinez
— fellow intense anti-communists.

50.12.8. In this February, 1984 meeting in Miami held between
"Paco" Chanes and Vidal and Corbo, Chanes gave his final
approval to the participation of Vidal and Corbo in the
assassination of Eden Pastora.

50.12.9. Vidal and Corbo then sought advice from Chanes as to
whom they might retain to carry out this assassination.
Paco Chanes sent Vidal and Corbo to meet with Frank
Castro and Rolando Martinez.

50.12.10. Vidal and Corbo met with Frank Castro and Rolando
Martinez in Miami in February of 1984 and were, in turn,
sent to see one Niles Heinz. Heinz, in turn, sent Vidal
and Corbo to meet with one Ramon Cecilio Palacio — a
man reported to be the "chief of security" in Miami for
Jorge Ochoa.

50.12.11. In February of 1984, Vidal and Corbo met, in Miami, with
Ramon Cecilio Palacio - who placed them in the hands of

two Cuban brothers introduced to them as Ricardo and
William "Gris". These two men arc believed by
Plaintiffs* CounscTs sources to be, in fact, one Raul
Villavcrdc and one of his two brothers - either Rafael
(if he was not earlier killed in a yacht explosion in
Miami) or Jorge, a cocaine smuggler associated with
Palacio and Ochoa.

50.12.12. The "Gris" brothers took the men to Chile and introduced
them to Amac Galil, a notorious international right-wing
terrorist who was, at the time, working for the dreaded
secret military police of Chilean dictator Pinochet.

30.12.13. Galil was paid $50,000 to plan and execute the
assassination of Eden PaJtora.

50.12.14. Between March and May of 1984, Amac Galil travelled
through Panama up into Costa Rica - where he went to
John HulPs ranch. On John HulTs ranch, Galil obtained
from John Hull three kilograms of C-4 explosive -
portions of which had been smuggled onto John Hull's
ranch through the combined efforts of Defendants
Theodore Shackley, Thomas Clincs, Richard Sccord, Albert
Hakim, Rafael "Chi Chi" Quintcro, John Hull, Bruce
Jones, Thomas Posey, Ronald Martin, James McCoy, and
Mario Delamico.

50.12.15. John Hull met repeatedly with Galil while Galil was in
Costa Rica. Indeed, John Hull travelled with Galil, by
car, from HulPs ranch, up to the Nicaraguan border,
where Galil took numerous photographs of the area, and
then returned with Hull to Hull's ranch. These facts
have been independently corroborated by Plaintiffs'
Counsel by direct interviews between our investigators
and two sources who were eyewitnesses to Galil's
presence on John Hull's ranch prior to the La Penca
bombing. These are Sources #32 and #33.

50.12.16. In May of 1984, Amac Galil left John Hull's ranch and
took up residence at the Grand Via in San Jose, where he
used the false identity of a Danish journalist by the
name of Per Anker Hansen.

50.12.17. Under this false identity, Galil obtained employment
with a Swedish film crew and, later, obtained access to
the press conference held by Eden Pastora at La Penca on
May 30, 1984.

50.12.18. Galil detonated the C-4 bomb concealed in an aluminum
camera case - using a remote control radio transmitter
— killing, maiming, and severely injuring the
international journalists and parties listed in the

Plaintiffs' Complaint on May 30, 1984.

50.12.19. As described by Cruz and Saenz to David, Galii escaped
in the following manner: he fled using a truck owned by
Defendant Hull with assistance of various of the other
defendants.

Kidnappings, Death Threats, and Murder

51. At the conclusion of one of the several interviews held between Carlos
and David in a public park in San Jose, Costa Rica, in 1985, David and
Carlos were seized on the sidewalk next to the park by a small group of
armed men whom David later identified to Carlos as associates of John Hull
and Hull's International Brigade of Contras.

These men forced David and Carlos, at gunpoint, onto the floor of the
back seat of a car and drove them, for hours, to the main ranch of John
Hull, at the northern border of Costa Rica. There David and Carlos were
held by an armed guard, in a small wooden shed, while the other men went "to
contact John."

David told Carlos that David was sure that the men were going to kill
David and Carlos when they returned so he persuaded Carlos to join with
him in an escape. David and Carlos attacked the lone armed guard left to
detain them, broke the window out of the shed in which they were held
captive, and fled into the forest — amid a hail of gunfire from their
guard.

52. After days and nights spent in the forest, David and Carlos came to a
road, obtained a ride on a truck to a small village - and Carlos telephoned
Tony Avirgan and asked that Avirgan come to get them.

53. David refused to go with Avirgan and effect his escape, wanting to get
away from the situation which was threatening his life. So, David left
Carlos, who waited in a park to be picked up by Tony Avirgan. David
promised, however, that he would contact Carlos to let Carlos know that
David was safe."

The Plaintiffs were later informed by a member of the Costa Rican Rural
Guard, Source #34, that an agent of the Costa Rican Rural Guard placed
undercover on John Hull's ranch. Source #35, reported to Costa Rican
authorities that he had later seen David recaptured and physically brought
to John Hull's ranch where David was beaten and tortured to death on John
Hull's ranch.

54. Carlos reported his kidnapping to the Costa Rican legal authorities and
these authorities searched, with Carlos, for the property, and the wooden

David did not call and the next day Carlos, trailed by Avirgan and a
Costa Rican police officer, found David in the Central Market area. David
assured Carlos that he was fine and would soon leave the country and from
there would be in touch. Neither Carlos nor the Plaintiffs ever heard from
or saw David again.

shed, where Carlos and David had been held. This search by the authorities
lead to the ranch of John Hull on the Costa Rican-Nicaraguan border.

55. Soon after the reported recapture and torture-execution of David,
Plaintiffs Tony Avirgan and Martha Honey began to receive telephoned death
threats - ordering them "to stop your investigation or be killed.** These
threats then began to take the form of notes, made up of letters from the
alphabet cut from magazines, notes which were physically placed under the
door of their home — where they lived with their two small children.

These death threats, and similar death threats directed to their
employees and office staff, required the Plaintiffs to spend thousands of
dollars to install a physical security system in their office and home. The
continued death threats required the Plaintiffs to send their children out
of the country to stay with the Plaintiffs' family in New York State and
to live Hinder an armed guard provided to them by the Costa Rican legal
authorities, Source #36.

56. After a thorough investigation of the information provided to them by
David, by Carlos - and by numerous other sources; including Costa Rican law
enforcement authorities. Sources #37 and #38; ARDE Intelligence Officials,
Sources #39 and #40; interviews with Defendant Felipe Vidal himself. Source
#41; and interviews with former Contra members. Sources #42, #43, #44, and
#45 - Plaintiffs Tony Avirgan and Martha Honey prepared a written report of
their findings and publicly released this report at a press conference held

in San Jose, Costa Rica In the Fall of 1985.

57. After this report, Carlos Rojas Chinchilla was kidnapped, a second

time, by associates of John Hull. These men seized Carlos from his house in
San Jose and, at gunpoint, ordered him to copy, in his own handwriting, a
prepared statement they showed him - stating that he had been told nothing
by David about John Hull - and that his earlier reports filed with the
Costa Rican legal authorities about David's reports, and Carlos' kidnapping
by associates of John Hull's were all made up by Carlos at the demand of
journalists Tony Avirgan and Martha Honey.

Carlos was told by these men that, after writing this, Carlos would be
released, unharmed but that, in two weeks time, Carlos would, again, be
contacted by these men and brought before a "specially selected" group of
journalists where Carlos was to publicly release his written statement and
renounce his police reports about John Hull.

After writing the demanded statement, Carlos was released and he
fled to Tony Avirgan and Martha Honey and requested protection.

The Plaintiffs assisted Carlos in escaping from Costa Rica with his
family and secured a safe place for him to remain until he was called
upon to testify in the trial of John Hull.

All of these facts have been verified directly to Plaintiffs' Counsel
Daniel Sheehan in personal interviews between Attorney Sheehan and Carlos
Rojas Chinchilla.

58. In the Fall of 1985, Defendant John Hull sued Plaintiffs Avirgan and
Honey in Costa Rica, charging them with criminal libel.

59. In the Fall of 1985, I was contacted by a Source, Source #46, and was

informed about Plaintiffs Avirgan and Honey's information from David and

their numerous other sources — and, finding thai this information was

closely related to information provided to the Christie Institute by our

Sources regarding the smuggling of guns, ammunition and explosives to John

HulPs ranch from Florida, via Ilopango Air Force Base in El Salvador, I

asked that my Source #46 have Tony Avirgan and Martha Honey contact me so

we could cooperate in our respective investigations.

60. For a period of time. Source #46 communicated information back and
forth between our Christie Institute investigation and Tony Avirgan and
Martha Honey.

In December of 1985, my law office was asked by Tony Avirgan and Martha
Honey to assist in the preparation of their defense against the charges of
criminal libel in Costa Rica. We agreed to do so.

The Secret Team

61. During my preliminary investigation of the information in the
possession of Tony Avirgan, Martha Honey and their sources - I was contacted
by Source #47, a right-wing para-military specialist, former U.S. Army pilot
in Vietnam and military reform specialist in January of 1986.

Source #47, the Specialist, who was unaware of my investigation,
informed me that he had met - at a right-wing function - a former U.S.
military intelligence officer. Source #48, interested in seeing to it that
the Mujahedin forces in Afghanistan were supplied with safe and effective
military equipment with which to combat the Soviet invasion of their
homeland.

Source #47 informed me, however, that, upon his second meeting with
Source #48. this source began to discuss with Source #47 the existence of a
"Secret Team" of former high-ranking American CIA officials, former high-
ranking U.S. military officials and Middle Eastern arms merchants -- who
also specialized in the performance of covert political assassinations of
communists and "enemies" of this "Secret Team" which carried on its own,
independent, American foreign policy - regardless of the will of Congress,
the will of the President, or even the will of the American Central
Intelligence Agency.

Source #47 was so shocked at this information that he wanted me to meet
with Source #48, to interview him, and to evaluate the information this man
had.

I agreed to do so. The meeting was set up for February, 1986, at the
home of Source #47 outside of Washington, D.C.

The Wilson Connection in Iran

62. In February of 1986, I went to the house of Source #47, and was
introduced to Source #48. He was a former U.S. intelligence officer who
served in Iran in 1976 and for a period thereafter.

In our interviews. Source #48 set forth the details of a highly secret
assassination project which operated in Iran from 1976 until the fall of the
Shah - under the supervision of Defendant Theodore Shackley and Defendant

Thomas Clincs. This project was supervised, in the Middle East by one Edwin
Wilson. Source #48 who worked as an anti-terrorist specialist in the
U.S. Military Mission in Iran, was in a special position to have personal
knowledge about the project run by Edwin Wilson - since Wilson's program
operated under the rubric of an "anti-terrorist" project.

Source #48 set forth, in detail, how this covert "anti-terrorist"
search and destroy operation was set up, in 1976, under the overall
supervision of the Assistant Deputy Director of Operations for the American
Central Intelligence Agency - Theodore Shackley, and his Deputy, Thomas
Clines. However, Source #48 was convinced that this operation became a
criminal, privately run, non-CIA authorized program as of 1977 - after
President Jimmy Carter and CIA Director Stansfield Turner entered the
government.

This privately-run, "anti-terrorist" assassination program was
authorised and controlled by Theodore Shackley and Thomas Clines - in their
purely private, non-governmental capacity, from 1977 to 1979.

During this 1977 to 1979 period, Edwin Wilson, in his private capacity
as the field director of this private Shackley-Clines project, established
contact, in Libya, with Mohammar Gadhafi and secretly agreed to train Libyan
anti-Shah of Iran terrorists in the use of deadly C-4 explosives at five
secret terrorist training camps located inside Libya. While entirely
criminal in nature, Edwin Wilson's activities with these Libyan terrorists
were actually intelligence-gathering activities - designed to put into his
hands the identities, missions and targets of the Libyan, anti-Shah
terrorist operations.

Once this intelligence information was obtained by Wilson in his
capacity as a trainer and supplier for the terrorists, Wilson would secretly
communicate the identities, and mission of particular terrorists to Rafael
"Chi Chi" Quintero - who was responsible for "interdicting" and directing
the assassination of these Libyan terrorists.

Indeed, part of the "mission" of Wilson inside Libya was to carry out
the assassination of Mohammar Gadhafi himself. Pursuant to this plan,
Wilson arranged for Gadhafi's plane to be "wired-up" and bombed. The plane
was blown up - but, at the last moment before the plane took off, Gadhafi
returned from the tarmac to receive a telephone call. Several East German
agents were killed in the explosion.

This operation of Wilson's was "blown" when one of Wilson's associates
here in the United States, one Kevin Mulcahey, unknowingly revealed to a
person friendly with an agent of the Federal Bureau of Alcohol, Tobacco and
Firearms, that his boss, Edwin Wilson, was training and supplying Libyan
terrorists.

Wilson and his associate Frank Terpil were indicted for their dealings
with Gadhafi - but his supervisors, Theodore Shackley and Thomas Clines,
were allowed to resign from the CIA by CIA Director Stansfield Turner and
Deputy Director Frank Carlucci.

However, upon resigning. Defendants Shackley and Clines joined with
Defendants Secord and Hakim and "went private" - continuing to run their
"Secret Team" - complete with it's own covert foreign policy.

Plaintiffs' Counsel learned this information not only from Source #48,
but also from Source #49 - who is a retired CIA officer with knowledge about
this operation and a Source #50 - who is a former Air Force officer of the
Special Investigation Office who investigated Edwin Wilson's activities in

the Middle East.

Source #49 has had direct conversations with Source #50 who was
directly involved with Edwin Wilson in this Middle Eastern Operation.

Supplying the Contras

Source #49 has direct knowledge that it was this "Secret Team" of
Defendant Shackley, Defendant Clines, Defendant Secord and Defendant Hakim -
operating through their business partnership with Edwin Wilson named the
Egyptian-American Transport and Service Company (incorporated in January of
1979) who first established contact with and began secretly supplying
weapons, ammunition and C-4 explosives to the Contras soon after they began
operations in Honduras in August of 1979 and who later, under a separate
corporate cover, supplied C-4 explosives and military equipment to the
Contras, through John Hull, in Costa Rica in 1983 and 1984. The "Field
Officer" for this "Secret Team" was Defendant Rafael "Chi Chi" Quintero,
the man who met with the field commanders of the Contras in Honduras and the
Contra associates of John Hull in Costa Rica to take their "orders" for
weapons and explosives and who saw to it that said military supplies were
delivered. Defendant Quintero conducted his activities on behalf of this
Secret Team through a Florida-based corporation named Orca Supply Company -
a company earlier set-up by Edwin Wilson.

This information was obtained by Plaintiffs' Counsel from Source #49
and from persons who have spoken directly with persons directly involved in
this operation.

Under the supervision of Defendant Theodore Shackley, Defendants Thomas
Clincs, Richard Secord, Albert Hakim and Rafael Quintero have been directly
responsible for the private supplying of military equipment - including the
C-4 explosives supplied to John Hull in 1983 and 1984 which were used in the
terrorist bombing attack at La Penca on May 30, 1984. Indeed, a close
associate of Defendant Quintero trained persons in Honduras to make deadly
C-4 anti-personnel terrorist bombs identical to the one used at La Penca.
This individual was one John L W. Harper. These Defendants were
responsible for the entire supply of weapons, ammunition and explosives to
the Contras in Honduras and Costa Rica from August of 1979 up to October of
1986 " with the exception of the time period between June of 1981 and March
of 1984, during which time American CIA Director William Casey and his agent
Vincent M. Cannistraro supplied such materials.

Defendants Martin, McCoy, Delamico, Posey and Chancs contributed
military supplies directly to this flow of equipment supplied by Defendants
Shackley, Clines, Secord, and Hakim during this time period - including a
portion of the C-4 used to construct the C-4 bomb used at La Penca in the
attempted assassination of Eden Pastora.

Moreover, Ricardo and William "Gris" are reported, by a source. Source
#51 - a former Contra member active in the Miami area with direct knowledge
of the Miami Contra community - to be one Raul Villaverdc and his brother,
either Rafael or Jorge Villaverdc. The Villaverde brothers are close
associates of Defendant Rafael Quintero, who worked with Defendant Quintero
as professional assassins for Edwin Wilson in Iran and Libya between 1976
and 1980. According to Source #51, it was in Iran and Libya, while working
for Wilson, that Raul and Rafael Villaverde met Amac Galil, the right-wing,

anti-Gadhafi Libyan terrorist whom the Defendants actually procured to carry
out the La Penca bombing.

63. In April of 1986. Plaintiffs' Counsel was introduced to Source #52 a
high-ranking, active. Central Intelligence Agency official who discussed

with Sources #48 and #49 the activities of Defendant Shackley and Clines and
confirmed to them a number of the facts set forth above.

64. At that time. Plaintiffs' Counsel also met personally with Source #53
another high-ranking, active. Central Intelligence Agency official, who
confirmed much of the data concerning the political environment and
activities of persons involved in the Contra movement in Costa Rica in 1984
- and the names of the persons involved in the Contra operations in Costa
Rica in 1984. at the time of the La Penca bombing.

65. In early 1986. Plaintiffs' Counsel established contact with Source #54
a man actively engaged in the trafficking of cocaine with Defendant
Francisco "Paco" Chancs and Defendant Dagoberto Nunez, which source
communicated to Plaintiffs' Counsel detailed information confirming the
participation of Defendants Chanes. Nunez, and Hull in the smuggling of
cocaine into the United States through Miami and Memphis. Source #54
supplied Plaintiffs' Counsel with the names and whereabouts of some half-
dozen pilots who flew guns, ammunition and C-4 explosives from the United
States to John Hull's ranch in Costa Rica - and who flew cocaine back into
the United States from Defendant Hull's ranch. A number of these pilots
have been located and contacted by Plaintiffs' Counsel, but they insist upon
immunity from criminal prosecution in exchange for their testimony against
the Defendants in this case. These pilots constitute Sources #54, #55 #56
#57, #58. and #59. '

66^ Plaintiffs' Counsel has established direct contact with Edwin Wilson
who IS serving a federal prison term in excess of 50 years at Marion Prison
in Illinois and has spent hours in private interviews of Wilson. Mr Wilson
also requests immunity from criminal prosection in exchange for his
testimony demonstrpting the truthfulness of the information set forth above
about his activities with Defendants Shackley. Clines. Secord, Hakim and
Quintero. Edwin Wilson is Plaintiffs' Source #60.

67. Plaintiffs' Counsel has also personally interviewed Source #61 a Costa
R. can pilot with intimate knowledge of the cocaine smuggling operations of
Defendants Hull and Nunez - and of the fact that the income from their
smuggling activities is being used to fiance the Contra operations of the
Defendants in Costa Rica. Source #61 introduced Plaintiffs' Counsel to
Source #62. a Roman Catholic Priest from Costa Rica who has personally
interviewed numerous peasants in Costa Rica who have come to know with
direct personal knowledge of Defendants Hull and Nunez cocaine smuggling
operations - and their partnership in these operations with Defendant
Francisco "Paco" Chancs in Miami.

68. Plaintiffs' Counsel's investigators have interviewed Sources #63 #64

who tJ. Z^^ ,V\'''''''7/^''u,' °'" ^^"« Enforcement Administration

who are directly knowledgeable concerning the cocaine smuggling operation of

Defendants Chanes, Vidal, Corbo, Nunez, Hull, Ochoa and Escobar and the use
of a portion of the profits from this enterprise to fund their Contra
operations in Costa Rica.

69. Plaintiffs' Counsel has personally interviewed Source #66, an active
Florida state law enforcement intelligence officer, who is familiar with the
drug smuggling — and illegal gunrunning operations of the defendants — but
who has been directed to "stand clear" from his investigation of their
activities.

The First "Contra War": Organized Crime and Right-wing Terror-Politics

70. Sources #48 and #49 j^jcscribed above, as well as Sources #67 and #68,
who are tenured professors at accredited universities in the U.S. who
conduct professional research into government documents, interview persons
in the U.S. intelligence community, and teach accredited courses regarding
the history of the activities of our American intelligence community — as
well as Source #69, who is a retired official of the United States Customs
Department and the Federal Bureau of Narcotics and Dangerous Drugs (now the
Drug Enforcement Administration), and Source #70, who is a former Southeast
Asian Border Police officer, and Source #71, who is a retired CIA official -
- have communicated evidence to Plaintiffs' Counsel which constitutes
probable cause to believe that the following facts are true regarding the
Defendants in this case:

70.1. That, in late 1959, immediately after Fidel Castro drove
Dictator Batista out of Cuba, former United States Vice President
Richard M Nixon established, and chaired, a Special Committee within
the United States National Security Council with the express assignment
of developing -- and executing — a plan by means of which to mount a
covert "Contra" war against the socialist government of Cuba, utilizing
expatriate indigenous right-wing Cubans who had been loyal to Dictator
Batista. The objective of this non-Congressionally authorized
operation was to undermine, weaken, and eventually, overthrow the
revolutionary socialist government of Cuba. It appears that this
secret operation was then code-named "Operation 40."

70.2. That, in late 1959, then Vice President Richard M. Nixon,
with the direct participation and cooperation of United States Central
Intelligence Agency Director Allen Dulles, undertook the supervision of
the recruiting of expatriate, right-wing Cubans who had fled from Cuba
to Miami, Florida — and caused to be established two secret military
training bases for their "Contra" forces, one south of Miami, Florida,

and one in Guatemala. CIA Director Allan Dulles assigned CIA Agent and
former Marine Corps officer Carl Jenkins to supervise the training of
these "Contra" forces in guerilla warfare tactics in Florida and
Guatemala. The objective of this Nixon-Dulles supervised operation was
to train and to secretly infiltrate these expatriate Cubans back into
Cuba, where they would set up centers of guerilla military resistance
to the Castro-led socialist government. These forces would also mount
terrorist military attacks against the economic infra-structure of

Cuba, making it difficult for the new revolutionary government to
organize and operate the economy.

70.3. With this covert NSC-CIA program underway in early 1960, then
Vice President Richard M. Nixon secretly "reached out" to one Robert
Maheu, the Chief of Staff and de facto Director of billionaire Howard
Hughes* financial empire. At the time Maheu was working with Nixon on

a secret, non-Congressionally approved project which may have involved
underwater activities and been named "Operation Desktop". Because of
Maheu's secret status known only to Richard Nixon and President
Eisenhower, Richard Nixon selected Maheu to attend an equally secret
meeting, in early 1960, in Florida, with two men representing former
Havana Mafia "Don" Santo Trafficante - whose fabulously wealthy Havana
Casino, Hotel and prostitution operation run by Resorts International,
Inc. (a Meyer Lansky Mafia company) had been driven out of Cuba, along
with Trafficante's business associate Batista in 1959.

70.4. At this early 1960 Florida meeting between Robert Maheu
(representing Richard Nixon ) and John Roselli and Sam Giancana
(representing Santo Trafficante, a Meyer Lansky Mafia Lieutenant), it
was agreed between Richard Nixon and Santo Trafficante that the NSC's
secret Operation 40 would be secretly "supplemented" by secreting,
within this operation, a "private" sub-operation which was to be
supervised directly by the Mafia's Havana Lieutenant Santo Trafficante.
This secret, "private" unit was to be a political assasslnatloD unit
assigned to murder Cuban President Fidel Castro, his brother Raul
Castro. Che Guevera and five other revolutionary Cuban government
leaders.

Former associates of Cuban dictator Batista and of Resorts
International boss Santo Trafficante were, according to this early 1960
Nixon-Trafficante agreement, to be selected out of the Operation 40
participants by Santo Trafficante - and then secretly trained, as
political assassins, by Trafficante and his Mafia associates, at a
secret "Triangular-Fire Training Base" to be located in Mexico. Those
selected from Operation 40 by Santo Trafficante to become members of
the "Shooter Team" were:

Rafael "Chi Chi" Quintero;

Felix Rodriguez (AKA "Max Gomez");

Luis Posada Carriles (AKA "Ramon Medina**);

Rafael Villaverde;

Raul Villaverde;

Ricardo Chavez;

Frank Fiorini (AKA Frank Sturgis);

Rolando Martinez; and two other Cuban Americans.

One of the "supervisors" of the group was to be E. Howard Hunt,
code-named "Eduardo."

This secret "Shooter Team" began training in early 1960.

''OJ. When John F. Kennedy received the Democratic Party nomination

for President in the Summer of 1960, he was briefed by a CIA officer

about the existence of Operation 40 and its objectives -- but it does
not appear that he or Robert Kennedy were ever briefed about the
existence of the Shooter Team. However the Shooter Team continued to
tram - and. indeed, between I960 and 1963, initiated several efforts
to assassinate Cuban President Fidel Castro.

'°'^-.„ . January of 1961 and April of 1961, the low-profile

gucrilla-inf titration strategy of Operation 40 was transmuted in a plan'
for a full-scale military invasion of Cuba, to be staged at the now-
infamous Bay of Pigs. This invasion, using the personnel of Operation
40, failed disastrously in April of 1961.

70.7. However, by June of 1961. Robert Kennedy had rc-grouped the
tattered remnants of the old Operation 40 forces and re-initiated the

old low*-profiIc. strategy of infiltration and guerrilla "raids" into
SlJtV J ! Operation 40 was named "Operation Mongoose." This

fZ JuJ^of .o7,\"'m""'k'^ ""y'''" •^""^^y Administration

irom June of 1961 to November of 1963.

Th-«H '^\!:''^"'"^°\?^ "Operation Mongoose" was. then 34.year-old,
Theodore Shackley. His Deputy was Thomas Clines
Lieutenli'r' °P"''';°%/."''ctioning in a working partnership with Mafia
Lieutenant Santo Trafficante. operated from a base located in a few

the «o7rlr?„"„ University of Miami. This base - and

the operation itself - came to be called "JM/Wave"

operations - and their associated Trafficante-
lead political assassination sub-operation - were directed by Theodore
Shackley and Thomas Clines from 1961 to 1963. mcoaore

70.8. During 1963. several participants in Operation 40 were caueht
smuggling narcotics into the U.S. from Cuba and the use. by tie '
program, of former Batista and Trafficante criminal associates in the
program began to cause "problems of control" of illegal "pro teering "

;;e'"ShoTrTeam."" ^''"''"-^ " « ''^^ ^P"--- of

Daflas. Texas. °^ ^""^^^ assassinated in

70.10. In 1965. "Operation Mongoose." and JM/Wave wen* .i,..t a,.^^
and Jheodore Shackley and his D/puty,' Thoma^Sre? w7r7 t^sfer^rld" to

The Move to Southeast Asia: Political Assassination Financed by Opium

s?alion for thiri!"' T''=o<'o;'= Shackley was made the Deputy Chief of
station for the CIA in Laos. Thomas Clines became his Deputy.

n?nvi-i.w • Shackley and Thomas Clines secretly

whTch Van"p,'r'"''' ^''^ ^ «hree-sided war in

which Van Pao was engaged, in Laos, for control of part of the illeaal
opium trade in that nation. During 1965. Van Pao's competitors in ?hl

,t 'J i li l lt i!JLj l.' 'i f .. ' ^ * i. 'i .lMU.g W t

opium trafficking business were mysteriously assassinated.

By 1966, Van Pao was one of the major opium producers and
traffickers in Laos.

70.13. Under the direction of Deputy Chief of Station Theodore
Shackley and his Deputy, Thomas Clines, a secret program was pursued to
train indigenous Hmong tribesmen in guerilla war tactics for use in
"unconventional warfare" activities. These activities included the art

of political assassination. Starting in 1966, their "special

operations" with the Hmong tribesmen began to be secretly financed by

Van Pao.

70.14. In 1964, a "Special Operations Group" was established in
Saigon, Vict Nam. This group was a multi-service, military operation
known as the Military Assistance Command, Vietnam Special Operations
Group (MACV-SOG) or the Joint Task Force for unconventional warfare.

This group, among other tasks, "supervised" the secret political
assassination activities of this secret unit of Hmong tribesmen --
though the group operated, in fact, under the supervision of Theodore
Shackley and Thomas Clincs.

From 1966 to 1968, the commander of the Special Operations Group,
which supervised the political assassination program in Laos, Cambodia,
and Thailand, was Defendant General John K. Singlaub.

Serving under Singlaub in Laos for a period at the end of 1968 was
a young 2nd Lt. by the name of Oliver North.

The Deputy Air Wing Commander for the Special Operations Group was
then Air Force Lt. Col. Richard Sccord out of Udorn AFB, Thailand. His
superior was then Col. Harry C. "Hcinic" Aderholt.

One of the members of the Army Special Forces units in the Group
was one Dwight Owen - the older brother of Defendant Robert Owen.

Between 1966 and 1971, this Special Operations Group based in Laos
was, in fact, under the supervision of Theodore Shackley and Thomas
Clincs. During the period from 1966 to 1975, this Special Operations
Group in Laos, through the secret Hmong tribesmen unit funded by a
portion of Van Pao's opium income, secretly assassinated over 100,000
non-combatant village mayors, book-keepers, clerks and other civilian
bureaucrats in the countries of Laos, Cambodia and Thailand.

70.15. In 1966, Theodore Shackley became CIA Chief of Station in
Laos when former Station Chief Gordon Jorgenson was made Chief of
Station in Vietnam. Thomas Clincs continued to be a Deputy to Shackley
in Laos. In early 1968, Shackley became Chief of Station in Saigon.

70.16. In 1968, Theodore Shackley's former associate in the JM/Wave
program in Miami, Mafia Lieutenant Santo Traf f icante, flew from Tampa,
Florida, to Southeast Asia where he met at a hotel in Saigon with
Shackley's Laotian associate Van Pao. In this meeting, Santo
Trafficantc agreed to become a partner with Van Pao in the importation

of China White heroin into the United States. By 1969, Santo
Trafficantc had become the #1 importer and distributor of China White
heroin in America. Van Pao's profits increased accordingly ~ as did
his financial contribution to the secret Hmong tribesmen assassination

and "unconventional warfare" project supervised by Theodore Shackley
and Thomas Clincs in Laos, Cambodia and Thailand.

70.17. In early 1972, Theodore Shackley and Thomas Clines were
transferred from Saigon to the United States, where Theodore Shackley
became the Chief of the CIA's Western Hemisphere operations. Thomas
Clines became his Deputy. This division of the CIA directs the
operations of the CIA in Central and Latin America.

From this post, Theodore Shackley and Thomas Clines directed the
operation known as "Track IP in Chile which directed the political
assassination of Chilean socialist President Salvador Allende and his
Chief of Staff in Chile and the military overthrow of the
democratically elected government of Chile in September of 1973.

70.18. Shortly before the successful overthrow of the socialist
Chilean government in September of 1973, Theodore Shackley and Thomas
Clines were transferred to Langley, Virginia; Shackley headed the East
Asia Division with Clines as his Deputy.

70.19. From this post at Langley, Theodore Shackley and Thomas
Clincs directed the Phoenix Project in Vietnam in 1974 and 1975 which
carried out the secret mission of assassinating members of the economic
and political bureaucracy inside Vietnam to cripple the ability of that
nation to function after the total US withdrawal from Vietnam. This
Phoenix Project, during its history, carried out the political
assassination, in Vietnam, of some 60,000 village mayors, treasurers,
school teachers and other non-Viet Cong administrators.

70.20. Theodore Shackley and Thomas Clines financed a highly
intensified phase of the Phoenix Project, in 1974 and 1975, by causing
an intense flow of Van Pao opium money to be secretly brought into
Vietnam for this purpose.

This Van Pao opium money was administered for Theodore Shackley
and Thomas Clincs by a US Navy official based in Saigon's US office of
Naval Operations by the name of Richard Armitage.

Armitage functioned as the "bursar" for their Van Pao opium funds
into the Vietnam Phoenix Project from 1973 to the fall of Vietnam in
April of 1975.

The Birth of the Secret Team

70.21. However, because Theodore Shackley, Thomas Clines and Richard
Armitage knew that their secret anti-communist extermination program

was going to be shut down in Vietnam, Laos, Cambodia, and Thailand in
the very near future, they, in 1973, began a highly secret non-CIA
authorized program setting up their own private anti-communist
assassination and unconventional warfare program - to operate after
the end of the Vietnam campaign.

70.22. Thus, from late 1973 until April of 1975, Theodore Shackley,
Thomas Clines and Richard Armitage disbursed, from the secret, Laotian-

based. Van Pao opium fund, vastly more money than was required to
finance even the highly intensified Phoenix Project in Vietnam. The
money in excess of that used in Vietnam was secretly smuggled out of
Vietnam in large suitcases, by Richard Secord and Thomas Clines - and
carried into Australia, where it was deposited in a secret, personal
bank account (privately accessible to Theodore Shackley, Thomas Clines
and Richard Secord).

During this same period of time between 1973 and 1975, Theodore
Shackley and Thomas Clines caused thousands of tons of U.S. weapons,
ammunition, and explosives to be secretly taken from Vietnam and stored
at a secret "cache" hidden inside Thailand. The Van Pao monies in this
secret Australian account and this large cache of stolen US weapons
hidden deep inside Thailand were to be used by Theodore Shackley,
Thomas Clines, Richard Secord, Richard Armitage and the right-wing
covert operations operatives they could persuade to join their "off-
lincs", private "secret team" after the conclusion of the Vietnam
campaign.

70.23. The "liaison officer" to Shackley and Clines and the Phoenix
Project in Vietnam, during this 1973 to 1975 period, from the "40
Committee" in the Nixon White House was one Eric Von Marbod - an
Assistant Secretary of State for Far Eastern Affairs. Von Marbod
shared his information about the Phoenix Project directly with his
supervisor Henry Kissinger.

70.24. Saigon fell to the Vietnamese in April of 1975. The Vietnam
War was over.

Pott-Vletnam: Drugs, Arms Scams and Terror Contioue

70.25. Immediately upon the conclusion of the evacuation of U.S.
personnel form Vietnam, Richard Armitage was dispatched, by Theodore
Shackley and Thomas Clines, from Vietnam to Tehran, Iran.

70.26. In Iran, Armitage (the -bursar"for the Van Pao opium money
for Shackley and Clines* planned "Secret Team" covert operations
program), between May and August of 1975, set up a secret "financial
conduit" inside Iran, into which secret Van Pao drug funds could be
deposited from Southeast Asia. The purpose of this conduit was to

serve as the vehicle for secret funding, by Shackley's "Secret Team,"
of a private, non-CIA authorized "Black" operations inside Iran -
disposed to seek out, identify, and assassinate socialist and communist
sympathizers -- who were viewed by Shackley and his "Secret Team"
members to be "potential terrorists" against the Shah of Iran's
government in Iran.

70.27. In late 1975 and early 1976, Theodore Shackley and Thomas
CImes retained Edwin Wilson to travel to Tehran, Iran to head up the

Secret Team" covert "anti-terrorist" assassination program in Iran.
This was not a U.S. government-authorized operation. This was a
private operation supervised, directed and participated in by Shackley,

Clincs, Sccord and Armitagc in their purely private capacities.

70.28. At the end of 1975, Richard Armitagc took the post of a
"Special Consultant" to the U.S. Department of Defense regarding
American military personnel Missing In Action (MIAs) in Southeast Asia.
In this capacity, Armitagc was posted in the U.S. Embassy in Bangkok,
Thailand.

There Armitagc had top responsibility for locating and retrieving
American MIA's in Southeast Asia. He worked at the Embassy with an
associate, one Jerry O. Daniels.

From 1975 to 1977, Armitagc held this post in Thailand. However,
he did not perform the duties of this office. Instead, Armitagc
continued to function as the "bursar" for Theodore Shacklcy's "Secret
Team," seeing to it that secret Van Pao opium funds were conducted from
Laos, through Armitagc in Thailand to both Tehran and the secret
Shackley bank account in Australia at the Nugen-Hand Bank. The monies
conducted by Armitagc to Tehran were to fund Edwin Wilson's secret
anti-terrorist "seek and destroy" operation on behalf of Theodore
Shackley.

Armitagc also devoted a portion of his time, between 1975 and
1977, in Bangkok, facilitating the escape from Laos, Cambodia and
Thailand and the re-location elsewhere in the world, of numbers of the
secret Hmong tribesmen group which had carried out the covert political
assassination program for Theodore Shackley in Southeast Asia between
1966 and 1975. Assisting Richard Armitagc in this operation was Jerry
O. Daniels. Indeed, Jerry O. Daniels was a "bag-man" for Richard
Armitagc, assisting Armitagc by physically transporting out of Thailand
millions of dollars of Van Pao's secret opium money - to finance the
re-location of Theodore Shackley's Hmong tribesmen and to supply funds
to Theodore Shackley's "Secret Team" operations.

At the U.S. Embassy in Bangkok, Richard Armitagc also supervised
the removal of arms, ammunition and explosives from the secret
Shackley-Clincs cache of munitions hidden inside Thailand between 1973
and 1975 - for use by Shackley's "Secret Team." Assisting Armitagc in
this latter operations was one Daniel Arnold, the CIA Chief of Station
in Thailand - who joined Shacklcy's Secret Team - in his purely
private capacity.

The U.S. Ambassador to Thailand, one Morton Abramowitz, came to
know of Armitage's involvement in the secret handling of Van Pao opium
funds and caused to be initiated an internal State Department heroin
smuggling investigations directed against Richard Armitagc.

Armitagc was the target of Embassy personnel complaints to the
effect that he was utterly failing to perform his duties on behalf of
American MIAs, and he reluctantly resigned as the D.O.D. Special
Consultant on MIA*s at the end of 1977.

From 1977 until 1979, Armitagc remained in Bangkok opening and
operating a business named The Far East Trading Company. This company
had offices only in Bangkok and in Washington, D.C. This company was,
in fact, from 1977 to 1979, merely a "front" for Armitage's secret
operations conducting Van Pao opium money out of Southeast Asia to
Tehran and the Nugen-Hand Bank in Australia to fund the ultra right-
wing, private anti-communist "anti-terrorist" assassination program and

•unconventional warfare" operation of Theodore Shackicy's and Thomas
Cline's "Secret Team." During this period, between 1975 and 1979, in
Bangkok, Richard Armitage lived in the home of Heinie Aderholt the
former Air Wing Commander of Shacklcy's "Special Operations Group" in
Laos who, between 1966 and 1968, had served as the immediate
superior to Richard Secord, the Deputy Air Wing Commander of MACV-SOG.
Sccord, in 1975, was transferred from Vietnam to Tehran, Iran.

Early "Irjin Arms DeaP Profit-SkimmiDg

70.29. In 1976, Richard Secord moved to Tehran, Iran and became the
Deputy Assistant Secretary of Defense in Iran, in charge of the Middle
Eastern Division of the Defense Security Assistance Administration. In

this capacity, Secord functioned as the chief operations officer for
the U.S. Defense Department in the Middle East in charge of foreign
military sales of U.S. aircraft, weapons and military equipment to
Middle Eastern nations allied to the U.S.. Secord's immediate superior
was Eric Von Marbod - the former 40 Committee liaison officer to
Theodore Shacklcy's Phoenix program in Vietnam from 1973 to 1975.

70.30. From 1976 to 1979, in Iran, Richard Secord supervised the
sale of U.S. military aircraft and weapons to Middle Eastern Nations.
However, Richard Secord did not authorize direct nation-to-nation sales
of such equipment directly from the U.S. government to said Middle
Eastern governments. Instead, Richard Secord conducted such sales
through a "middle-man", one Albert Hakim.

By the use of middle-man Albert Hakim, Deputy Assistant Secretary
of Defense Richard Secord purchased U.S. military aircraft and weapons
from the U.S. government at the low "manufacturer's cost" - but sold
these U.S. aircraft and weapons to the client Middle Eastern nations at
the much higher "replacement cost." Secord then caused to be paid to
the U.S. government, out of the actual sale price obtained, only the
lower amount equal to the lower manufacturer's cost. The difference,
was secreted from the U.S. government. Secord and Albert Hakim
secretly transferred these millions of dollars into Shackley's "Secret
Team" operations inside Iran - and into Shackley's secret Nugen-Hand
bank account in Australia. Thus, by 1976, Defendant Albert Hakim had
become a partner with Thomas Clines, Richard Secord and Richard
Armitage in Theodore Shackley's "Secret Team."

70JI. Between 1976 and 1979, Shackley, Clines, Secord, Hakim,

Wilson, and Armitage set up several corporations and subsidiaries
around the world through which to conceal the operations of the Secret
Team. Many of these corporations were set up in Switzerland. Some of
these were: (1) Lake Resources, Inc.; (2) The Stanford Technology
Trading Group, Inc.; and (3) Companie dc Services Fiduciares. Other
companies were set up in Central America, such as: (4) CSF,
Investments, Ltd. and (5) Udall Research Corporation. Some were set up
inside the United States by Edwin Wilson. Some of these were: (6) Orca
Supply Company in Florida and (7) Consultants International in
Washington, D.C.

Through these corporations, members of Theodore Shacklcy's "Secret
Team** laundered hundreds of millions of dollars of secret Van Pao opium
money and pilfered Foreign Military Sales proceeds between 1976 and
1979.

70.32. In January of 1979, Theodore Shackley, Thomas Clines, Richard
Sccord and Albert Hakim made Edwin Wilson a full partner in their
"Secret Team" gunrunning board, establishing the corporation named the
Egyptian-American Transport and Services Corporation.

The Contra Coonectioa: The Secret Team Bargains with Somoza

70.33. In the Spring of 1978, Shackley, Clines, Secord and Hakim
directed Edwin Wilson to travel to Nicaragua to make available to
Nicaraguan dictator Anastasio Somoza. the private assassination
services of Shackley's "Secret Team" - the objective of which was to
carry out the location of and the political assassination of the top
leadership of the Sandinista revolutionary movement. This contract was
tendered, and Wilson offered the assassination services of Shackley's
•Secret Team" to Somoza, in the Spring of 1978, for the sum of $650,000
per year. This offer included the services of five (5) "counter-
subversion specialists," at the price of $80,000 per year each and an
annual expense account of $250,000 for the operation. One the five
•specialists" was to be Defendant Rafael "Chi Chi" Quintero. The
others were to be members of the 1960 Richard Nixon-Santo Trafficantc
"Shooter Team" assembled for Operation 40 (members of which were used
as "operatives" for Shackley's political assassination operations form
1961 to the present).

Somoza felt that the price tag was too high for this project so
he continued to negotiate for a lower price.

Persons who know of this 1978 approach to Somoza by Wilson on
behalf of Shacklcy, Clines, Secord and Hakim are one Douglas
Schlachter, Source #72, (presently in the Federal Witness Protection
Program), one Christine Simmons, Source #73, and former United States
Congressman Charles Wilson, Source #74.

70.34. Again, in the Spring of 1979, Theodore Shackley, Thomas
Clines, Albert Hakim and Richard Secord sent Edwin Wilson to arrange a
contract relationship between the "Secret Team" and Nicaraguan dictator
Anastasio Somoza.

This time, the contract offer was to supply military equipment,
ammunition and explosives to Somoza - since Somoza's dictatorial
government had been cut off from any supply of military equipment from
the U.S. by President Jimmy Carter's invocation of the Harkin Amendment
m early 1979.

While Edwin Wilson's trip to Somoza in the Spring of 1979 did not
result in the establishment of this contract, the trip of Rafael "Chi
Chi" Quintero, later, did. Thus, by early 1979, Theodore Shackley,
Thomas Clines, Albert Hakim and Richard Secord (all partners together
in this Egyptian-American Transport and Service Company) had a formal
contractual relationship with Nicaraguan dictator Anastasio Somoza

pursuant to which tjiis "Secret Team" supplied weapons, ammunition,
aircraft and explosives to Somoza's Nicaraguan government - despite
the formal order of the United Slates President Jimmy Carter that no
military equipment of any kind was to be provided to Somoza's
Nicaraguan government.

70.35. Neither President Carter nor his Director of Central
Intelligence, Stansficld Turner, knew or approved of the conduct of
Theodore Shackley and his partners who supervised the Secret Team -
because Shackley and Clines had been ordered by Stansfield Turner to
resign from the CIA in late 1978 or early 1979 - when Turner learned
that Shackley and Clines were business partners with Edwin Wilson who
was going to be publicly indicted (based on the disclosures of Kevin
Mulcahey) for unlawfully supplying military explosives and weapons to
Libya.

70.36. From March to July of 1979, Shackley's "Secret Team" supplied
military equipment to Somoza in his capacity as the Dictator of
Nicaragua. The man who met regularly with Somoza's representative to
arrange these weapons shipments was Rafael "Chi Chi" Quintero.

The CIA Takes the Ball

70.37. When Somoza fled from Nicaragua on July 17, 1979, he

travelled to an island in the Bahamas named North Cay. There he met
with Rafael "Chi Chi" Quintero and other representatives of Theodore
Shackley and his Secret Team associates.

In their July, 1979 meetings on North Cay, representatives of
Theodore Shackley, Thomas Clines, Richard Secord and Albert Hakim
entered into a contract to supply aircraft, weapons, ammunition, and
military explosive to Somoza and his La Guardia Generals who had fled
Nicaragua with him, to enable them, now as "Contras", to plan and
prosecute - against the U.S. government-recognized Sandinista
government of Nicaragua - a secret covert Contra war virtually
identical to the one which Theodore Shackley and Thomas Clines had
supervised against the socialist revolutionary government of Cuba from
1961 to 1965.

The man who met regularly with the Contra military field
commanders, to advise them as to what weapons-and equipment they
needed - and to see to it that this equipment was supplied to the
Contras from 1979, through 1980, into 1981, was Rafael "Chi Chi"
Quintero. He conducted his weapons supply activities through the
Miami-based company named Orca Supply Company, a company set up by
Edwin Wilson.

These secret supply operation to the Contras by Shackley's "Secret
Team" continued until June of 1981 - when the United States CIA
Officially (though covertly) took over this operation and assigned
Vincent M. Cannistraro to take the place of Rafael "Chi Chi" Quintero
as the Supply Officer" for the Contra operation.

North Turns to the Secret Team When Congress Bans Aid

70.38. When the United States Congress was drafting the Boland
Amendment in late 1983 to order the CIA and the White House to cease
all United States Executive Department aid to the Contras, Lt. Colonel
Oliver North contacted Theodore Shackley, Thomas Clincs, Albert Hakim
and Richard Secord and had the "Secret Team" re-activate its military
supply of the Contras' operations which also included the John Hull
Contra operation in Costa Rica on the "Southern Front" against
Nicaragua. Rafael Quintero, again, became the "Supply Officer" for the
Honduran and Costa Rican Contra operations.

70.39. As of March of 1984, the Defendants' "Secret Team" was, once
again, back in charge of the secret supplying of aircraft, weapons,
ammunition and military explosives to the Contra forces in Honduras and
through John HulTs ranch in Costa Rica.

It was between March of 1984 and May of 1984 that Defendants
Shacklcy, Clines, Secord, Hakim, Quintero, et al. supplied to John Hull
~ along with Defendants Posey, Martin, McCoy, Delamico et al. the
C-4 military explosives used by the right-wing Libyan terrorist Amac
Galil to bomb the May 30, 1984 La Penca press conference of Eden
Pastora.

70.40. It was also this same group of men who supplied the C-4
explosives that were to be used in the terrorists' bombing attack
against the United States Embassy in Costa Rica in July of 1985,
described in the Plaintiffs' Amended Complaint.

White House Uses Secret Team Again for Iranian Arms Deal
Profits go to the Contra Operations

71. Also, when Ronald Reagan, Edwin Meese, William Casey, and Robert
McFarlanc, John Poindexter and Oliver North decided, in 1985 and 1986, to
undertake the secret sale of arms to Iran, it was, once again, this "Secret
Team" of Theodore Shackley, Thomas Clines, Albert Hakim and Richard Secord
to whom they went to carry out this "black" mission. Plaintiff's sources
for this information are Sources #49 and #50. They arc the sources for all
the information in paragraph 71.

71.L This "Secret Team" employed its tried and tested procedure of

purchasing the military equipment from the U.S. Pentagon at
"manufacturer's cost" and selling the equipment to Iran at "replacement
cost" - and conducted the "excess" profit earned in the sale, through
Lake Resources, Inc., Companie de Services Fiduciares and in to its
Grand Cayman account in the name of CSF Investments, Ltd. - where the
"Secret Team" kept on deposit the funds which it secretly used to
finance its Contra war against the socialist government of Nicaragua.

71.2. Secret Team member Richard Secord purchased short take-off

and landing (STOL) airplanes for the Contra forces in Honduras and
Costa Rica - which planes were used to ferry weapons and explosives

into John Hull's farm from Ilopango Air Force Base in El Salvador.
Sccord purchased there four STOL aircraft from Maule Inc., paying for
said aircraft with two checks one drawn on the account of CSF
Investments, Ltd. and the other drawn on the account of Udall Research
Corporation.

'^^•3- Rafael "Chi Chi" Quintero personally participated in the

supervision of the construction of the dirt landing strips inside Costa
Rica which were used for the smuggling into Costa Rica of weapons,
ammunition, and military explosives - the construction of which secret
landing strips were financed by checks drawn on the account of Udall
Research Corporation.

7^1.4. Defendants Albert Hakim, Richard Sccord and Thomas Clines arc

all associated with the company of Stanford Technology, Inc. and

Stanford Technology Trading Group, Inc.. The registered agent of the

office of Stanford Technology Trading Group, Inc. located in

Switzerland is also the registered President of CSF Investments, Ltd.

in the Grand Cayman Islands and Defendant Hakim has paid an official

court settlement of a private lawsuit with a check drawn on the account

of CSF Investments, Ltd..

Telephone calls placed from the secret "safe house" in El
Salvador, where Eugene Hasenfus and the other crew members who flew
arms and munitions to the Contra forces in Central America lived, went
to the offices of Secord's, Clines' and Hakim's company Stanford
Technology, Inc..

72, Plaintiffs' Counsel has a direct eyewitness, Source #75. who can
identify Felix Rodriguez as the man who, along with Luis Posada Carriles,
supervised the unloading of weapons and ammunition flown in from Florida to
Ilopango Air Force Base in El Salvador by Defendant Thomas Posey and who
then trans-shipped said equipment to Defendant John Hull's ranch in Costa
Rica.

And Plaintiffs' Counsel has a source. Source #76, who can testify that
this same Felix Rodriguez is, in fact, a long-timc employee of Defendant
Theodore Shackley indeed, that this Felix Rodriguez has, for many years
worked as an employee of Defendant Shackley in Theodore Shackley's private
"Secret Team" weapons supply and assassination program.

Conclusion

73. Plaintiffs' Counsel represents to the Court that he is in contact with
other sources who possess further, first-hand, evidence proving the
truthfulness of the civil and criminal charges made against the 29
Defendants in the Plaintiffs' Amended Complaint - and that these sources
include Eden Pastora himself. Source #77, high-ranking officials in the
Costa Rican government and elsewhere. Sources #78 and #79, - which the
Court's short 20 day period allowed for the Plaintiffs' preparation of their
Opposition to the Defendants' Motion to Dismiss did not allow Plaintiffs'
Counsel adequate time to contact.

74. Plaintiffs' Counsel also represents to the Court that Plaintiffs would
easily be able to provide numerous additional sources to prove the
truthfulness of the facts set forth in this Attorney's Affidavit, if the
Court were to afford the Plaintiffs the standard opportunity for civil
discovery.

75. Also, Plaintiffs' Counsel asks that the Court take Judicial Notice of
the fact that numerous reports have been published in The New York Times .
Thp Wa?hinRt9n Pq§^ The San Francisco Examiner , and many other national
newspapers setting forth details of the conduct of some of the Defendants in
this civil action which corroborate their participation in the covert
criminal enterprise to violate the United States Neutrality Act by
unlawfully waging war against the nation of Nicaragua - which is the
"enterprise- reported by the Plaintiffs to this Court in May of 1986. While
such reports are certainly not dispositive of the issue of the Defendants'
participation in the criminal enterprise described in the Plaintiffs'
Amended Complaint, the fact that the Plaintiffs and the Plaintiffs' Counsel
have been the source of information to the Court, so much of which has now
been publicly revealed to the Court by the national media and by Congress to
have been entirely accurate, most certainly should dispel any remaining
doubts that the Court may have had, at one time, that Defendants' Attorney
Ted Kline was incorrect when he publicly asserted to the media that "The
Plaintiffs' case is just a Clown Act". This case is no "Clown Act". It is

a serious endeavor to bring the legal process of the Judicial Branch of our
Federal government to expose, to evidence, and to prove the factual
assertions made against the Defendants in this case by the Plaintiffs.

76. Plaintiffs alio ask the Court to take Judicial Notice of the fact that
Defendants Richard Secord and Robert Owen appeared before United States
Congressional committees on December 9th and 10th of this year and asserted,
under oath, that their being required to testify about their possible
participation in a criminal enterprise to covertly provide funds and weapons
to the Central American Contra forces would result in testimony which would
tend to incriminate them or provide direct evidence of their guilt of some

of the federal crimes with which the Plaintiffs' Counsel publicly charged
them before this Court on May of 1986.

Surely this conduct of only the first of the Defendants named in this
federal civil suit to be placed under oath and asked about their
participation in the criminal "enterprise" alleged in this Complaint is
probative of the criminal guilt of the Defendants of some of the crimes

charged in this Complaint.

77. Plaintiffs and Plaintiffs* Counsel, The Christie Institute, possess
evidence constituting "probable cause" that each of the Defendants named in
this Complaint are guilty of the conduct charged.

If further detailed evidence is required by the Court to allow the
Plaintiffs to begin the standard process of discovery in this case, the
failure to place it in this Affidavit is the function of the short time
allowed by the Court for the preparation of this filing — it is not because
the Plaintiffs lack such evidence.

Daniel P. Sheehan

Martha Honey watches as her husband, Tony Avirgan, arrives at the hospital to be treated for
injuries suffered at the La Penca bombing. Photo: Maria Esquivel,

Attorney Daniel P. Sheehan: General Counsel for Tony Avirgan, Photo by Julio Lainez, Tico Times.
the Christie Institute, Sheehan leads its effort to
bring the private citizens behind the Contras to jus-
tice.

John Hull during his libel trial against Martha Honey,

Avirgan and Honey, Hull's suit was dismissed. Photo by Julio Lainez, Tico Times.

Photo by Julio Lainez, Tico Times.

Moments after the explosion. Tony Avirgan is in the checkered shin. Reid Miller
of Associated Press is in a white shirt. Photo by Jose Venegas. La Nacion .

Major General John K. Singlaub, U.S. Army (Ret.):
He openly helped organize the illegal private
contra supply network in the United States.

Major General Richard Secord. U.S. Air Force (Ret.):
A principal Secret Team member, he illegally uses
drug pro fits to provide contra guns and explosives.
Photo: U.S. Air Force

Selected Index

Abramowitz, Morton (38)
Adcrholt, Hcinic (35), (39)
Allen, Richard (14)

Armitagc. Richard (36), (37), (38), (39)
Arnold, Daniel (38)

Avirgan, Tony (1), (14), (17), (21), (26), (27X^28)
Brigade 2506 (24)

Bush, Vice President George (14), (16)
Calcro, Aldofo (13), (22), (23), (24)
Cannisiraro, Vincent M. (15), (30), (41)
Carlucci, Frank (29)
Carr, Steven (12)
Carriles, Luis Posada (33), (43)
Carter, President Jimmy (14), (29), (41)
Casey, William (14). (15), (16), (30), (42)
Castro, Fidel (32), (33), (34)
Castro, Frank (24)

Chanes, Francisco "Paco" (24), (30), (31), (32)
Chavez, Ricardo (33)

Chinchilla, Carlos Rojas (17), (18), (19), (20), (21), (23), (26)
(27)

Civilian Military Assistance (10), (11)
Claridgc, Duanc "Dewey" (22)

Clincs, Thomas (25), (29), (30), (31), (34), (35), (36), (37), (38)
(39), (40), (41), (42), (43) v / ^ ^

Cocaine (19), (22), (23), (24), (25), (31)

I t

1 »i<'.rr.vy?*y,;r^fww^6 ^ ?i y7f r wtfv ^^

Companic dc Services Fiduciares (39), (42)
Consultants International (39)
Corbo, Rene (23), (24), (32)

Costa Rica (10), (11), (13), (18), (19), (20), (21), (22), (24), (25),
(26), (27). (28), (30), (31), (32), (42), (43)

Cruz, Alvaro (23), (24), (26)

CSF Investments (42), (43)

Daniels, Jerry O. (38)

David (18). (19), (20), (21), (22). (23). (24), (26), (27). (28)
Dclamico, Mario (25). (30). (42)
Dulles, Allen (32)

Egyptian-American Transport and Service Company (30), (40)

Eisenhower, President Dwight (33)

El Salvador (4), (5), (11). (15), (28). (43)

Escobar, Pablo (19). (23). (24), (32)

Far East Trading Company (38)

Federal Emergency Management Agency (FEMA) (5), (6), (7)

Fiorini, Frank (33)

40 Committee (37), (39)

Friends of the Americas (8)

Galil, Amac (25), (26), (30), (42)
Garcia, Jesus (11)
Giancana, Sam (33)
Glibbcry, Peter (12)
Gomez, Max (33)
Gordon, Jorgenson (35)
Grand Cayman (42), (43)

Gray and Company (16)
Gris Brothers (25), (30)

Hakim, Albert (25), (29), (30), (31), (39), (40), (41), (42), (43)
Hansen, Per Anker (25)
Hascnfus, Eugene (43)
Heinz, Nilcs (24)

Honey. Martha (1), (14), (17), (21), (27), (28)

Hull, John (1 1), (12), (13), (14), (17), (18), (19), (20), (21), (22),

(23), (24), (25), (26), (27). (28), (30), (31), (32). (42),
(43)

Hunt, E. Howard (33)
Ilopango Air Base (II). (28), (43)

International Brigade (18), (19), (20), (21), (22), (23), (26)
Iran (28), (29), (30), (37), (39), (42)
Jenkins, Carl (32)
Jenkins, Woody (8)
JM/Wave (34), (35)
Jones, Bruce (12), (14), (20), (22), (25)
Kennedy, Presic'ent John F. (1), (33), (34)
Kennedy, Robert (34)
Kissinger, Henry (37)
Lake Resources, Inc. (39), (42)
Lansky, Meyer (33)
Mafia (33), (34), (35)
Mahcu, Robert (33)

Martin, Ronald Joseph, Sr. (25), (30), (42)
Martinez. Rolando (24), (33)

^ *» *«

Mattes, Jim (12)

Maulc Inc. (43)

McCoy, James (25), (30), (42)

McFarlanc, Robert (16), (42)

Medina, Ramon (33)

Mccse, Edwin (7), (14), (16), (42)

Merki, Staccy (3), (4), (12)

MIAs (38)

Mitchell, Attorney General John (7)
Mr. Shrimp (24)

Nicaragua (4), (4), (8), (9), (10), (11), (14), (15), (16), (18),
(19), (21), (22), (23), (40). (41), (42), (44)

Nixon, Former President Richard (3), (7), (32), (33), (37), (40)

North, Lt. Col Oliver (12), (13), (16), (35), (42)

Nugcn-Hand Bank (34), (38), (39)

Nunez, Moises Dagoberto (31), (32)

Ocean Hunter, Inc. (24)

Ochoa, Jorge (19), (23). (24), (25), (32)

Operation 40 (32), (33), (34), (40)

Operation Mongoose (34)

Opium (34), (35), (36), (37), (38), (40)

Orca Supply Company (30), (39), (41)

Owen, Dwight (35)

Owen, Robert (12), (13), (16), (35), (44)
Palacio, Ramon Cecilio (24), (25)

Pastora, Eden (10), (13), (19), (22), (23), (24), (25), (30), (42),
(44)

Phoenix Project (36), (37), (39)
Poindcxtcr, John (42)

Posey. Tom (10). (11). (12). (13). (14). (20). (25). (30). (42). (43)
Project Cable Splicer (7)

Quintcro, Rafael^Xhi Chi" (25), (29), (30), (31). (33), (40), (41).

Reagan, President Ronald (4), (5), (6), (7), (14), (15), (16), (42)

Resorts International (33)

REX 84 (5), (6), (7)

Rodriguez. Feliz (33), (43)

Roselli. John (33)

Saenz, Frcdcrico (23), (24), (26)

Schlachter. Douglas (40)

(35). (3.,.

Secret Team (^J). (29, (30,(36). (37). (38). (39). (40). (41).

Shacklcy. Theodore (25). (28). (29). (30). (31). (34) (35) (36^
(37). (37). (38). (39). (40). (il). (ij) '(43) " ^

Shcehan, Daniel (J), (27). (45)

Singlaub, Major General John K. (16). (35)

Somoza. Anastasio (14). (15). (22). (40), (41)

Special Operations Group (35). (39)

Stanford Technology Trading Group. Inc. (39). (43)
State Defense Force (5). (6). (8)
Sturgis. Frank (33)
Tambs. Lewis (19), (20)
Terpil, Frank (29)

Trafficantc, Santo (33). (34), (35), (40)

Turner, Siansficld (29), (41)

Udall Research Corporation (39), (43)

United States Council on World Freedom (16)

Van Pao (34), (35), (36), (37), (38), (40)

Vidal, Felipe (23), (24), (27), (32)

Villavcrde, Rafael (25)

Villaverde, Raul (25), (30). (33) *

Von Marbod, Eric (37), (39)

Wilson, Congressman Charles (40)

Wilson, Edwin (29), (30). (31), (37), (38), (39), (40), (41)